With the Safe Harbor Framework now officially invalid, all EU data transferred to the U.S. (including data already stored in the U.S.) are considered unlawful unless an alternative basis for transfer is used that adduces appropriate safeguards.
Benefits Think U.S.-EU safe harbor framework invalidation creates uncertainty
Dobelbower is a vice president and global benefits practice leader in Lockton Benefit Group. Reach him at (202)414-2495.