Head in the Clouds? A Brief Note on Transfers to the US in a Privacy-Absolutist World

After the Dutch National Cyber Security Centre published the Greenberg Traurig analysis of data transfers and the US CLOUD Act (https://lnkd.in/gmcvtCsP), we at Castlebridge HQ realized we needed to provide some practical guidance of our own on the state of hashtag#data hashtag#transfers, particularly to the hashtag#US.

This is an abridged version of what we shared with our clients today, but much of this will be relevant to any organisation facing the question of how to navigate in a hashtag#privacyabsolutist world.

I Think I Have Third Party Transfers Maybe Kinda Sorted?

Data transfers to third (or restricted) countries are a bit of a mess right now, and this has been made all the more messy by the UK trying to ‘get Brexit done’ by replacing EU laws and agreements with Brexity ones.

After puzzling over the question of what contract UK and EU exporters should be relying on, I decided to actually put it out on a whiteboard and share it with you. I hope this helps. Also, sorry.

I Filed a DSAR with NoybEU. Here’s Why.

At some point though, a thought came to me — what does a good tech stack look like? What kind of benchmark or best practice should I advise clients on? How can data controllers do things in a privacy-preserving way? And so I asked Noyb, CNIL and the Austrian DSB if they would, in the interests of transparency, share their tech stacks and best practice.

It didn’t go well.