Safe Harbor Invalidated – What's Next On The Chopping Block?

As I reported earlier today, the Court of Justice of the EU (ECJ) has declared Safe Harbor invalid. The full decision is now available online in English here (other languages also available at curia.europa.eu by searching on C-362/14).

There are two key elements of the ECJ's decision. The first is that national data protection authorities in the EEA are authorized – indeed, required – to hear complaints from individuals with regard to the transfer of their personal data outside of the EEA regardless of whether the Commission has issued an adequacy decision. The second is a determination that the Commission's adequacy decision concerning Safe Harbor is invalid. Period. It's gone.