Hamburg Data Protection Agency
After the European Court of Justice (ECJ) ruled that the Safe Harbor program is invalid, the European DPAs granted companies a transitory period until February to migrate from the Safe Harbor to other legal tools for their international data transfers, in particular by implementing Binding Corporate Rules (BCRs) or the Model Contractual Clauses.
The Hamburg Data Protection Agency (DPA), which effectively takes the lead in the German DPAs' response to Safe Harbour and the Privacy Shield, recently investigated 35 companies. It found significant shortcomings in that respect and has started to fine those for not having appropriate replacements for the Safe Harbor in place after the expiration of the permitted grace period.
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