It has taken several years but we have finally made it to the start line. The modernisation of European privacy laws has reached a critical milestone and with the formal adoption of the new data protection framework, we can now begin to lay the foundations for the future. Our guide “Future-proofing privacy” aims to be a useful starting point. 24 authors from 10 European Hogan Lovells offices have contributed their knowledge, efforts and advice to compile a unique resource of practical guidance. We have identified the key issues and explained why they matter. Crucially, we have approached the new framework with a practical mindset, providing concrete suggestions for actions to take now.
On 24 March, the French data protection authority, the CNIL, announced that it will soon make easier the practical implementation of intra-group transfers of data from French entities to entities located outside the European Union where groups of companies have adopted Binding Corporate Rules (BCRs). BCRs are becoming increasingly popular among multinationals as a legal means for providing adequate protection to personal data which are transferred from the European Union to countries that are not considered to provide an adequate level of protection by the European Commission. In the CNIL’s view, the implementation of BCRs shows a strong commitment from multinational organisations to protect personal data. Indeed, the CNIL has been a champion of the emerging “BCR for processors” initiative which is also prompting interest from sophisticated processors who operate globally.
The EU’s Work on Data Protection Reform continues following the vote of the EU Parliament’s Committee on Civil Liberties, Justice and Home Affairs (LIBE) on 21 October 2013 to adopt compromise amendments. The 104 compromise amendments represent a consolidation of proposals submitted by various European Parliament committees. Hogan Lovells has prepared a detailed analysis of the compromise amendments approved by the LIBE committee, which is attached to this post.