The European Union’s data-privacy regime is in transition. Between the Schrems v. Data Protection Commissioner decision of the European Court of Justice that invalidated the EU-U.S. Safe Harbor, the Irish data protection commissioner’s challenge to the model contract clauses, and new laws expanding both the scope and reach of European data protection, the once reliable systems of data transfer and jurisdictional understandings between the U.S. and the EU are not stable.
Companies in the U.S. should prepare for both new jurisdictional requirements and new data transfer requirements as replacement mechanisms start to be approved and implemented.
CHANGES FOR DATA COLLECTION
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