Tag Archives: Binding Corporate Rules

Hunton & Williams Privacy Professionals to Speak at the 2012 IAPP Europe Data Protection Intensive

Join Hunton & Williams at the 2012 Europe Data Protection Intensive, now hosted by the International Association of Privacy Professionals (“IAPP”) in London, April 25-26, 2012. Hunton & Williams privacy professionals will be featured speakers in the following sessions: Continue reading…

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Canadian Privacy Authorities Release Accountability Guidance

On April 17, 2012, the Office of the Privacy Commissioner of Canada and the Information and Privacy Commissioners of Alberta and British Columbia released guidance on their expectations for accountable privacy programs as required by Canadian law. The guidance, entitled “Getting Accountability Right with a Privacy Management Program,” discusses the building blocks of a comprehensive privacy program for businesses of all sizes. Although intended for a Canadian audience, the paper likely will have worldwide influence given recent privacy law developments around the globe.

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Article 29 Working Party Opines on Proposed EU Data Protection Law Reform Package

On March 23, 2012, the Article 29 Working Party (the “Working Party”) adopted an Opinion on the European Commission’s data protection law reform proposals, including the draft Regulation that is of particular importance for businesses. The Working Party’s Opinion serves as the national data protection authorities’ contribution to the legislative process before the European Parliament and the European Council.

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EU-U.S. Interoperability Not Ready for Prime Time

On March 19, 2012, the European Commission hosted this year’s Safe Harbor Conference in Washington, D.C., to address the transfer of data from Europe to the United States. Although it appears the Safe Harbor framework will remain unchanged for the time being, it seems unlikely the United States will be considered adequate, or even interoperable, with the EU for purposes of cross-border data transfers.

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2012 IAPP Global Privacy Summit

Join us at the International Association of Privacy Professionals (“IAPP”) Global Privacy Summit in Washington, D.C., March 7-9, 2012. Hunton & Williams privacy professionals will be featured speakers in the following sessions:

  • Mending Fences after a Breach
    Thursday, March 8, 12:15 p.m.
    Speakers include: Lisa J. Sotto, partner and head of the Global Privacy and Data Security practice, Hunton & Williams LLP; Susan Grant, Director of Consumer Protection, Consumer Federation of America; and Joanne B. McNabb, Chief, California Office of Privacy Protection. Continue reading…
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Hunton & Williams on the BCR Forefront

Shortly before Viviane Reding, Vice-President of the European Commission and Commissioner for Justice, Fundamental Rights and Citizenship, gave her keynote address on binding corporate rules (“BCRs”) at the IAPP Europe Data Protection Congress in Paris, Hunton & Williams co-authored two articles on BCRs with the French Data Protection Authority (“CNIL”):

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European Commission Drafts to Reform the EU Data Protection Framework Enter Interservice Consultation

In early December 2011, drafts of two legal instruments prepared by DG Justice of the European Commission to reform the EU data protection framework entered interservice consultation. This process will give other Directorates-General of the Commission the opportunity to comment on the drafts before they are formally released as legislative proposals; accordingly, changes to the drafts are likely. Following this comment period, the drafts will enter the EU legislative process, which is likely to take at least two to three years before they become law. It is believed that Justice Commissioner and Commission Vice-President Viviane Reding will formally announce final versions of the drafts at an appearance at the World Economic Forum in late January 2012.

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EU Commissioner Reding Promotes Use of BCRs at IAPP Congress in Paris

On November 29, 2011, at the International Association of Privacy Professionals (“IAPP”) Europe Data Protection Congress in Paris, France, Viviane Reding, Vice President of the European Commission and Commissioner for Justice, Fundamental Rights and Citizenship, provided insight into details of the proposals for the revised EU data protection framework. She focused explicitly on solutions for international data transfers, promoting Binding Corporate Rules (“BCRs”) as a solution that can offer a simplified, yet comprehensive, structure for safeguarding international flows of data. Commissioner Reding referred to BCRs as offering the possibility of consistent enforcement and legal certainty, without stifling innovation.

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Belgium Simplifies the Authorization Procedure for Binding Corporate Rules

On July 13, 2011, the Belgian Privacy Commission (the “Belgian DPA”) signed a Protocol with the Ministry of Justice which significantly simplifies the authorization procedure for binding corporate rules (“BCRs”) under Belgian law.  The Protocol was just made public on the Belgian DPA’s website.  View the Protocol on BCRs (in both Dutch and French).

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Council of Europe Considers Amendments to Convention 108

On June 28-30, 2011, the Council of Europe’s Bureau of the Consultative Committee of the Convention for the Protection of Individuals with regard to the Automatic Processing of Personal Data (known as the “T-PD-Bureau”) met in Strasbourg, France, to discuss, among other things, amending the Council of Europe’s Convention 108.  Convention 108, which underlies the European Union’s legal framework for data protection, is the only legally-binding international convention that addresses data protection.  Amendment of the Convention is thus closely linked to the current review of the EU data protection framework, and many of the same actors are involved in both exercises.

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