Following the decision that invalidated the Safe Harbor agreement (refer to our two most recent newsletters), media reports indicate that the supervisory authorities have likely reached a compromise regarding the transfer of data to the United States:

In contrast to previous statements issued by the data protection supervisory authority for Schleswig Holstein (“ULD”), it recently declared that is considers data transfers to the United States to be invalid even if EU standard contractual clauses or binding corporate rules and consent from the affected parties are used to provide additional security.

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