Here’s a good post on transfers of European private data to U.S. computers (from BakerHostetler). Of course, it’s in response to the October 6 decision by the E.U.’s Court of Justice, invalidating the Safe Harbor certification system. I think the best replacement for Safe Harbor, as of now, is the standard contractual clause system (SCC), mentioned under FAQ #3 in the post. (SCC’s are clunky, but we have to deal with clunky for the time being …)
I’ll have more to say on this later, as the dust settles.
© 2015 by David W. Tollen. All rights reserved.