CLARIFYING TWO AREAS OF CONFUSION ON PRIVACY SHIELD: SEPTEMBER 30, 2016, DEADLINE & EFFECT ON SWISS SAFE HARBOR
By James H. Koenig and Mary-Elizabeth M. Hadley
With the European Commission’s (“EC”) approval of the U.S.-EU Privacy Shield Framework (“Privacy Shield) on July 12, 2016, many companies are rushing to self-certify to the new compliance mechanism for personal data transfers from Europe to the United States. By certifying in the first two months – by September 30, 2016 – organizations can take advantage of a nine-month grace period from the date they certify to bring their existing commercial relationships and agreements with third parties into conformity with the Accountability for Onward Transfer Principle.
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