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Schrems II Judgements

If your company or your trusted service providers transfers personal information from the EU/UK to the US, including employee data or even data of US persons, the Schrems II European Court decision has profound significance — even if you do not rely on Privacy Shield.

This is a radical change to the adoption of Standard Contractual Clauses in practice, which impacts existing as well new transfers which rely on them. Not just for transfers to the US but all other “third countries” which do not have an adequacy decision from the EU Commission. If you want to continue to apply Standard Contractual Clauses as the solution for existing and new data transfers, these assessments of adequate protection for each particular datastream to each particular country will have to be triggered and recorded.

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Michael Bahar, Partner

Paula Barrett, Partner

Event register: The seismic shift of Schrems II: The future of data transfers from the EU and UK to the US
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