On 9 September, an article from Fox Rothschild LLP says that (following the effect of the Schrems II decision on EU-US transfers) Switzerland’s Federal Data Protection and Information Commissioner (FDPIC)  has determined that the US-Swiss Privacy Shield does not meet the “requirements of adequate data protection as defined by the FADP (Swiss Federal Act on Data Protection)”.   It issued a policy paper offering advice on transferring data to countries not on its list of nations with adequate safeguards.  The guidance provided includes that, when transferring data to non-listed countries, data exporters should conduct due diligence and, if necessary, contract clauses should be expanded.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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