Linklaters’ data protection specialists have met representatives of most of the German data protection authorities to discuss the impacts of the Safe-Harbor decision of the European Court of Justice on transfers of personal data to the US
- based on EU Model Clauses, Binding Corporate Rules (BCRs) and Intra-Group Agreements (IGAs); and
- requested by US authorities in the context of investigations.
What has happened so far?
On 6 October 2015 the European Court of Justice declared the Safe-Harbor decision of the European Commission (2000) invalid. Immediately thereafter, the question was raised whether this decision has an impact on other legal instruments originally designed to transfer personal data to the US (i.e. EU Model Clauses, BCRs and IGAs).