This morning, Germany’s Federal Data Protection Authority (DPA) announced that the European Data Protection Board (EDPB) has finalized an initial set of FAQs on international transfers in light of the recent Schrems II judgment. You can read our detailed analysis of the Schrems II judgment here. Initial reactions from European privacy enforcers are summarized here, along with an analysis of early EDPB guidance here.
Per Germany’s Federal DPA, the EDPB FAQs are envisioned to be a “living document.” The version published today will contain answers to questions that European DPAs were asked “very frequently” within the last week. They may be updated over time.
Germany’s Federal DPA provides a preview of some of the guidelines that will be in the FAQs:
According to the Federal DPA, the EDPB’s FAQs could be published as early as today. Alston & Bird will provide updates as these FAQs become available.