In the aftermath of the European Court of Justice’s (CJEU) invalidation of the Safe Harbor agreement, it was not immediately clear how quickly U.S. companies would need to find alternative vehicles for transferring data out of the EU, nor how they should accomplish this task. At least one of those questions has now been answered, with the EU Commission saying on Oct. 16 that the U.S. has until January 2016 to come up with an alternative framework to Safe Harbor.
From its meeting in Brussels, the Article 29 Working Party on the Protection of Individuals said in a statement last week, “If by the end of January 2016, no appropriate solution is found with the U.S. authorities and depending on the assessment of the transfer tools by the Working Party, EU data protection authorities are committed to take all necessary and appropriate actions, which may include coordinated enforcement actions.”
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