As we predicted last week, the European Commission has moved swiftly to issue an adequacy decision that formally adopts an agreement finalized with the US Department of Commerce in June concerning arrangements to legitimize the transfer of EU personal data to the US. The much anticipated “EU-US Privacy Shield” arrangements will replace the Safe Harbor regime, which was invalidated by the EU Court of Justice (CJEU) in October 2015.
Please see our alert for details about the path ahead, including key concerns, procedural and substantive requirements and the impact Brexit.