After the European Court of Justice invalidated Safe Harbor on
October 6, 2015, the Article 29 Working Party announced
in an October 16, 2015
statement that US companies that were Safe Harbor certified had
until the end of January 2016 to find alternative means to transfer
data to the US and, if they failed to do so, EU Data Protection
Authorities would pursue enforcement measures. DPAs in France,
Germany, and Ireland have all addressed these issues, but in
different ways.
France
The Head of the European Working Party, Isabelle
Falque-Pierrotin, is also the head of the French DPA, CNIL.
In 2015, CNIL investigated Facebook. On
January 26, 2016, CNIL found that Facebook was not compliant
with respect to cookies; CNIL also noted that Facebook transferred
data to the US based on the invalid Safe Harbor. CNIL requested
that Facebook stop transferring data to the US per the Safe Harbor
within 3 months. Since Facebook is now relying on Standard EU
Contractual
