Here's a reflection from the European Commission coming on the Schrems ruling that declared Safe Harbour invalid under EU Personal Data Privacy law [Directive 95/46/EC]. The EC seems to be looking for ways to annul the ruling, at least to reduce its disruptive impact on cross-border commerce. Here's a excerpt to contextualize the matter: *'The functioning of the Safe Harbour arrangement relied on commitments and self-certification of adhering companies. While signing up to Safe Harbour Privacy Principles and FAQs is voluntary, these rules are binding under U.S. law for those entities that have signed up to them and enforceable by the U.S. Federal Trade Commission."* They says they will conclude a new agreement to comply with the court ruling within 3 months but what's of heightened interest to me - and maybe those of us who been working at the WHOIS/RDDS/PPSAI kerfuffle - are the alternate mechanisms for cross-border transfers the EC is promoting as good and proper for annulment or reducing the impact of the court ruling. This aside, not the 'get-out-of-jail-card' they gave themselves: *"The present Communication is without prejudice to the powers and duty of the DPAs to examine the lawfulness of such transfers in full independence. It does not lay down any binding rules and fully respects the powers of national courts to interpret the applicable law and, where necessary, to make a reference to the Court of Justice for a preliminary ruling. Nor can this Communication form the basis for any individual or collective legal entitlement or claim. " * We certainly have jawed about these alternatives extensively in EWG discussions. Best, -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================