Is the EU-US DPF another Privacy Shield in the making?
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Strategic: Staying One Step Ahead
The EU–US Data Privacy Framework might look like the next big fix, but history suggests it could be undone just like Safe Harbor and Privacy Shield. UK privacy professionals should have a backup plan in place—think about reviewing your current data transfer routes and preparing to switch to Standard Contractual Clauses. It’s also wise to explore UK or EU-based hosting options if you handle sensitive information. These moves can help you handle any sudden rule changes with minimal fuss.
Tactical: Quick Wins for Today
First, do a simple audit: figure out which data transfers rely on the Framework and list any US service providers you’re using. Next, chat with vendors about flexible terms that allow easy switching to other legal mechanisms, such as SCCs. Finally, consider privacy management software to keep track of shifting requirements. These small steps can save a lot of trouble if the Framework gets challenged in court.
Insight
“The biggest threat to privacy is mass surveillance,” says Max Schrems, who has already toppled two EU–US agreements. Will this new version really hold up?
Ask yourself: if your customers asked where and how their data is stored, would you feel confident in your answer?
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