An earlier Alert, "German Privacy Regulators Issue Decision on Data Protection and Safe-Harbor Self-Certification of US Companies," analyzed the Düsseldorfer Kreis decision that appeared to undermine the US Department of Commerce's Safe Harbor framework, one of the routes that enables data on individuals in Europe to be transferred to the United States. Following the Düsseldorfer Kreis, another German decision has made data transfer out of Germany potentially more challenging.
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