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EU-U.S. Privacy Shield Principles Released

Client Alert | 2 min read | 03.01.16

On February 29, the U.S. Department of Commerce published the EU-U.S. Privacy Shield foundational documents, including the framework's updated principles. The European Commission (EC) published the draft adequacy decision for the new framework. While there are no major surprises in the documents, given the earlier press releases, publication will allow companies to begin planning compliance strategies.

For details on the differences between the previous framework (U.S.-EU Safe Harbor) and the new one, please join us on March 9 at Crowell & Moring in Washington, D.C. for a seminar on the EU-U.S. Privacy Shield and the forthcoming EU Data Protection Regulation (GDPR).

Crowell & Moring attorneys from our Brussels and D.C. offices will be joined by U.S. Department of Commerce Deputy Assistant Secretary Ted Dean, lead U.S. negotiator for the EU-U.S. Privacy Shield; and Oracle Vice President of Global Public Policy and Chief Privacy Strategist, Joseph Alhadeff. The seminar will focus on how the proposed framework/regulations differ from predecessors; adjustments to existing compliance programs that may be necessary to meet the new requirements; and hurdles/risks that may arise.

As for the implementation timeline of the EU-U.S. Privacy Shield, there remain several steps before the program is operational. The draft EU-U.S. Privacy Shield adequacy decision will now be subject to consultation by a committee of representatives of the EU Member States and their Data Protection Authorities (Article 29 Working Party), which will issue a (non-binding) opinion on April 12-13, 2016. Afterwards, the draft will have to pass the so called "comitology" (approval) process for EC decisions, which according to the EC, may take until June 2016. During that time, the U.S. will finalize the framework and put the agreed upon redress mechanisms in place.

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....