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While the Hamburg DPA was very quick off the mark, post ECJ Safe Harbor ruling, to announce its own investigation of Facebook's (and others') data transfer arrangements.
Organism and data transfer arrangements in place.
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But what shape any such future UK-EU data transfer arrangement could take remains tbc.
The issue has potential implications for the EU-US Privacy Shield datransferfer arrangement which currently enables close to 1,500 companies to authorize personal data transfers between Europe and the US.
The data transfer arrangement is now being probed by the European Union's data protection watchdog group, which is made up of representatives from all EU Member State DPAs.
Yet more pressure on the precariously placed EU-US Privacy ShiEuropean EUnionan Union parliament's civil liberties committee has called for the data transfer arrangement to be suspended by September 1 unless the US comes into full compliance.
And whether the EC really would be minded to pull the plug on a data transfer arrangement that it worked so very hard to push into place in the face of concerns about the adequacy of the privacy protections.
It is also controversial in Europe for effectively enabling the trampling of EU citizens' fundamental rights — a factor that helped derail a long-standing transatlantic data transfer arrangement, and continues to cause trouble for its replacement agreement (the EU-US Privacy Shield).
European privacy campaigner Max Schrems' legal challenge to Facebook has already been credited with the demise of a fifteen-year-old data transfer arrangement between the region and the U.S. last year, causing huge uncertainty for transatlantic data flows after Safe Harbor was suddenly struck down.
It's also worth noting that even some of these alternative legal bases are themselves facing legal challenges after data protection agencies expressed concern over their robustness, following the 2015 Europe Court of Justice decision to strike down the original Safe Harbor data transfer arrangement.
The data transfer arrangement, which is used by thousands of businesses to authorize transfers of EU users' personal data across the Atlantic, is under growing pressure ahead of an annual review this month, as the Trump administration has failed entirely to respond as EU lawmakers had hoped their US counterparts would at the time of the agreement being inked in the Obama era, back in 2016.
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