The Privacy Shield Survives Another EU Commission Review, For Now…

The EU Commission concluded its third annual review of the EU-U.S. Privacy Shield and found that it continues to provide an adequate level of protection for EU personal data. The program was created as a mechanism to facilitate transfers of personal data from the EU to the US. It is reviewed annually by the EU Commission, as we have discussed in prior posts. That body did express concern with some parts of the program. This included a fear that US Department of Commerce's monthly pro-active checks of companies may be too surface level, and did not necessarily include review of the companies' privacy provisions in vendor contracts.

Als of concern for the EU Commission was the focus -when trying to identify companies who falsely claimed to participate in the program- only on companies who had previously applied for certification. Instead, the Commission expressed, it would like to see all companies included in scope. The Commission also expressed its belief that there