👓This Month's Thematic Dossier: The Data Privacy Framework in Shambles, and What It Means to Businesses

Bonjour ☕

This month's thematic dossier analyses the recent shake-ups of the apparatus underpinning the EU-US Data Privacy Framework (DPF).

This dossier spans EU and US policy evolutions. I have also gone a little out of my usual ways, providing a few recommended actions to help you anticipate the future restrictions related to the suspension of the DPF.

The Data Privacy Framework (DPF), the framework for the transatlantic exchange of personal data between the US and the EU, is built on shaky foundations. Recent actions by the Trump administration—such as dismantling the Privacy and Civil Liberties Oversight Board (PCLOB)—threaten the framework's fundamental role of respect. Various hostile actions by the Trump administration could force the EU to rescind the DPF, destroying the legal basis for compliance with the EU GDPR.

Why It Matters. This uncertainty creates immediate compliance risks for businesses relying on the framework for data transfers. The European Commission faces mounting pressure to suspend the adequacy decision. Leaders urgently need to anticipate and secure these transfers, including identifying approaches to data localisation in the EU and impact assessments of transfers.