On August 11, 2021, the UK Information Commissioner’s Office launched a consultation on its draft international data transfer agreement and guidance for organizations on international transfers. Once finalized, the agreement will replace the existing EU Standard Contractual Clauses in the UK.
Continue Reading ICO Consultation on International Data Transfer Agreement to Replace SCCs

On June 21, 2021, the European Data Protection Board published the final version of its recommendations on supplementary measures in the context of international transfer safeguards, such as Standard Contractual Clauses.
Continue Reading EDPB Releases Final Recommendations on Supplementary Measures for International Transfers

On May 11, 2021, the European Parliament issued a press release requesting that the European Commission amend its draft decisions on UK adequacy to more closely align with EU court rulings and the opinion of the European Data Protection Board. The request came after the Parliament’s Civil Liberties Committee passed a resolution evaluating the Commission’s approach regarding the adequacy of the UK’s data protection regime.
Continue Reading MEPs Urge European Commission to Amend Draft UK Adequacy Decision

On April 27, 2021, the Portuguese Data Protection Authority ordered the National Institute of Statistics to suspend, within 12 hours, any international transfers of personal data to the U.S. or other third countries that have not been recognized as providing an adequate level of data protection.
Continue Reading Portuguese DPA Orders Suspension of U.S. Data Transfers by Agency That Relied on SCCs

On March 15, 2021, the state Data Protection Authority of Bavaria declared the use of U.S. e-mail marketing service Mailchimp by a fashion magazine in Bavaria impermissible due to lack of compliance with Schrems II mitigation steps for the transfer of e-mail addresses to the U.S.
Continue Reading Bavarian DPA Declares Transfers to E-mail Marketing Service Prohibited Due to Lack of Controller’s Assessment and Supplementary Measures

France’s highest administrative court recently issued a summary judgment that rejected a request for the suspension of the partnership between the French Ministry of Health and Doctolib, a leading provider of online medical consultations in Europe, for the management of COVID-19 vaccination appointments.
Continue Reading French Highest Court Rejects Suspension of Partnership with EU Service Provider Using AWS; Extends Application of the Schrems II Requirements

On December 9, 2020, the Senate Committee on Commerce, Science and Transportation held a hearing on the Invalidation of the EU-U.S. Privacy Shield and the Future of Transatlantic Data Flows. This post reviews the key topics, witnesses and views expressed during the hearing.
Continue Reading Senate Commerce Committee Holds Hearing on the Invalidation of the EU-U.S. Privacy Shield and the Future of Transatlantic Data Flows

On December 10, 2020, the Centre for Information Policy Leadership at Hunton Andrews Kurth submitted its response to the European Commission’s invitation for comments on its draft implementing decision on SCCs to be used for the transfer of personal data from a controller or processor subject to the GDPR to a controller or processor not subject to the GDPR.
Continue Reading CIPL Submits Response to European Commission’s Standard Contractual Clauses for the Transfer of Personal Data to Third Countries Pursuant to the GDPR