...that Act grants non-U.S. citizens among other rights, a private right of action for alleged privacy violations that occur in the U.S. but limits the right to sue to those citizens of countries that (1) permit the “transfer of personal data for commercial purposes” to the U.S., and (2) do not impose personal data transfer policies that “materially impede” U.S. national security interests. There are implications for the so-called Umbrella Agreement as well as the new Safe Harbour provisions. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================