Data Strategy Briefing — July 10, 2023

Executive briefing: On 10 July 2023 the European Commission issued Implementing Decision (EU) 2023/1795, granting the United States an adequacy finding under the EU–US Data Privacy Framework and restoring a lawful basis for commercial data flows that stalled after Schrems II.

Key data governance checkpoints

Transfer assessments. Update transfer impact assessments to document the new redress mechanisms, binding safeguards on U.S. intelligence access, and organisational accountability commitments.
Vendor assurance. Confirm that U.S. processors self-certify under the framework and publish privacy commitments covering onward transfers and data minimisation.
Fallback controls. Maintain standard contractual clauses and supplementary measures for scenarios where adequacy is challenged or for service providers outside the certification scope.

Operational priorities

Register monitoring. Track annual U.S. reviews and litigation risk so contingency plans can be triggered if adequacy is suspended.
Cross-border inventory. Catalogue data categories, processing purposes, and systems that now rely on the framework to simplify regulatory reporting.
Customer communications. Refresh privacy notices to explain the new transfer mechanism and available redress avenues for EU data subjects.

Enablement moves

Brief boards on the difference between the Data Privacy Framework, legacy Privacy Shield, and SCC obligations to set investment expectations.
Enhance vendor scorecards with recurring checks on certification status, complaint handling metrics, and data deletion workflows.

Sources

Zeph Tech helps multinational teams pressure-test cross-border controls, vendor onboarding, and redress playbooks under the renewed EU–US transfer regime.