McLellan, Felz and Beierlein Examine Data Transfer Sanctions in Wake of Safe Harbor Collapse

Articles / July 25, 2016

Counsel Melinda McLellan, Associate Jenna Felz and Staff Attorney Alexandra Beierlein authored an article, “Enforcement Outlook: German Data Protection Authorities Eye Cross-Atlantic Data Transfers,” which was published in Bloomberg BNA’s July 2016 World Data Protection Report. The article discusses fines levied by German authorities against three companies for unlawful transfers of personal data from the EU to the United States. The authors note that the October 2015 decision invalidating the Safe Harbor framework specifically authorized individual EU Member States, like Germany, to review companies’ data transfer practices to ensure compliance with EU law.

They conclude: “Based on these initial enforcement efforts, multinationals with operations in the EU would be well-advised to examine their data flows and ensure that they are not relying solely on a legacy Safe Harbor certification.”

Read the article.