On 3 December, an article from Hodgson Russ LLP reported that the US Department of Commerce issued recently a white paper addressing international data transfers pursuant to Standard Contractual Clauses (SCC) following the CJEU invalidation of the Privacy Shield in July.  The white paper addresses some of the issues with government access to data that the CJEU found problematic.  Overall, it says, the white paper provides useful material to companies relying on SCC.  It discusses the relevant law and has a number of citations to source documents that provide additional relevant information.  The guidance also suggests ways that companies can strengthen their SCC to demonstrate that an individual assessment of privacy protections has occurred.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

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

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s