Compliance Briefing — July 10, 2023

Executive briefing: On July 10, 2023, the European Commission adopted an adequacy decision for the EU–U.S. Data Privacy Framework. The decision recognises enhanced U.S. safeguards—including Executive Order 14086 redress mechanisms and intelligence collection limits—allowing certified companies to lawfully receive personal data from the European Economic Area.

Immediate compliance priorities

Certification assessment. Confirm whether existing Privacy Shield certifications transitioned automatically and, if not, submit updated self-certification packages to the U.S. Department of Commerce.
Privacy disclosures. Refresh public notices, intra-group transfer policies, and vendor contracts to reference the Data Privacy Framework principles and recourse processes.
Redress handling. Stand up escalation workflows for EU data-subject complaints, arbitration requests, and requests from the new Data Protection Review Court.

Control alignment

Governance. Assign senior privacy officers to oversee certification renewals, record-keeping, and annual verification obligations.
Security. Validate technical and organisational measures for personal data received under the framework, ensuring parity with Standard Contractual Clauses safeguards.
Vendor oversight. Audit downstream processors to confirm onward transfer clauses, complaint routing, and deletion processes meet framework requirements.

Enablement moves

Coordinate with EU legal counsel to reconcile Data Privacy Framework obligations with local supervisory authority expectations and potential future court challenges.
Update data transfer impact assessments reflecting the U.S. intelligence reforms and available redress channels.
Develop user-facing FAQs and DSAR templates describing access, correction, and opt-out rights available under the framework.

Sources

Zeph Tech helps multinationals manage cross-border transfer registers, recertification schedules, and incident escalation aligned to the Data Privacy Framework.