Data Strategy Briefing — March 25, 2022

Executive briefing: On 25 March 2022 the European Commission and the United States announced an agreement in principle on a Trans-Atlantic Data Privacy Framework, outlining privacy safeguards, redress mechanisms, and certification updates aimed at restoring lawful EU–U.S. data flows after Schrems II.^{White House fact sheet}^{European Commission press release}

Key governance checkpoints

Transfer impact assessments. Re-evaluate TIAs for U.S. transfers, incorporating the forthcoming safeguards on necessity, proportionality, and redress.
Certification readiness. Inventory current Privacy Shield certifications and plan resources for onboarding to the new framework once operational.
Redress mechanisms. Track commitments on an independent Data Protection Review Court and enhanced oversight to update incident and complaint workflows.

Operational priorities

Policy monitoring. Follow Commission draft adequacy decisions, U.S. Executive Order implementation, and EDPB guidance to time contract updates.
Stakeholder communications. Brief clients and partners on interim safeguards, emphasising encryption, access controls, and supplementary measures until the framework is legally effective.
Evidence retention. Document how supplementary controls mitigate surveillance risks so teams can demonstrate compliance during supervisory inquiries.

Enablement moves

Coordinate with legal counsel on aligning SCCs, Binding Corporate Rules, and prospective framework participation.
Map data flows to determine which business units benefit from the new certification pathway versus alternative transfer mechanisms.
Update executive dashboards summarising regulatory milestones, operational dependencies, and risk posture.

Sources

Zeph Tech guides transatlantic teams through transfer impact updates, certification readiness, and supplementary controls aligned to the announced framework.