CLARIFYING TWO AREAS OF CONFUSION ON PRIVACY SHIELD: SEPTEMBER 30, 2016, DEADLINE & EFFECT ON SWISS SAFE HARBOR

August 26, 2016

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.

See the full post at [_PH Privacy](http://www.paulhastings.com/publications-items/blog/ph-privacy/ph-privacy/2016/08/26/clarifying-two-areas-of-confusion-on-privacy-shield-september-30-2016-deadline-effect-on-swiss-safe-harbor)_