Today, the European Court of Justice (ECJ) issued its much-anticipated decision in the Schrems II case. As we analyze in detail in an earlier blog post, the ECJ’s decision invalidates Privacy Shield while leaving Standard Contractual Clauses (SCCs) formally intact – although relying on SCCs may become more complicated than in the past. A number […]
Germany
German DPA Announces GDPR Compliance Survey of Large Companies – Translation Provided
Following a two-year grace period, EU General Data Protection Regulation (GDPR) entered into force on May 25, 2018. For many companies, preparing for the GDPR was a multi-year project involving multiple teams and input or assistance from across the organization. On this blog, we have outlined the items we have seen as particularly time- or […]
German DPAs Issue DPIA Blacklists; Many Companies Likely to be Affected
The GDPR entered into force on May 25, 2018. One of the GDPR’s core going-forward obligations is the duty to conduct Data Protection Impact Assessments (DPIAs) over processing activities that create a “high risk” to individuals’ privacy. DPIAs constitute an important aspect of GDPR compliance, as they arguably replace the notifications of processing systems and […]
German DPAs to Survey Transfers in 500 Companies – with English Translation of DPA Questionnaire
Late last week, 10 of Germany’s 17 Data Protection Authorities (DPAs) announced they are planning to send written questionnaires to approximately 500 different companies regarding international data transfers. The following provides a brief overview of the situation, as well as an English translation of the questionnaire, for companies who are potentially affected. This summary refers […]
A Busy Month for German Data Protection
The European Court of Justice handed down its Schrems decision invalidating the Safe Harbor mechanism on October 6, 2015. Since then, companies have been looking to the Data Protection Authorities (DPAs) of EU member states to see how the decision would be interpreted and enforced. As many companies know, Germany is a multifaceted data-protection landscape. […]