- Key implications and next steps post Schrems II
- How are large businesses and SMEs in the EEA* that transfer personal data outside the EEA which relied on Privacy Shield or appropriate safeguards (eg SCCs or BCRs) under Article 46 responding to Schrems II?
- What steps should EEA* businesses which transfer personal data to the US or other jurisdictions outside the EEA take: (a) now; and (b) in the medium to longer term, if the transfer is not one of the limited number covered by an ‘adequacy decision’ issued by the European Commission?
Information Law analysis: Emma Ottoy, managing associate at Linklaters in the TMT/IP department and Richard Steppe, associate at Linklaters in the TMT/IP department consider the next steps for organisations transferring personal data following the landmark ruling on 16 July 2020 in Data Protection Commissioner v Facebook Ireland Ltd, Maximillian Schrems, Case C-311/18 (commonly known as ‘Schrems II’).
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