Predicted Privacy Shield Timeline for 2016 * Based on all currently available information from official government sources
2-month window for companies to sign-on early to gain additional 9-month period to fully implement required contracts and processes to meet all Onward Transfer obligations.
Official EU-US Privacy Shield Draft Text released.
Feb
4/12 – Article 29 Working Party Meeting to review Privacy Shield Draft Text. Influential Article 29WP Opinion to be released.
Mar
Apr
2-month “early sign-on” window closes. Any companies that submit to Privacy Shield after this date will not be placed on the DOC list as Self-Certified until they have all required operational changes in place immediately upon Self-Certification.
Final EU Ratification of EU-US Privacy Shield Framework anticipated. Program can begin. .
May
Jun
Jul
Aug
Sep 2016...............May 2017
Company A: Starts Early Builds new Privacy Shield practices and ensures sufficient preparation for early Privacy Shield sign-on.
Submission for Self-Certification complete with all required operational updates and verification documentation in place, including interim requirements for Onward Transfers.
Already on the DOC list as Self-Certified with 9 additional months to ensure all remaining Onward Transfer contracts and processes are fully in place.
Company B: Starts Later Tight timeframe to build required Privacy Shield practices. Ability to submit Privacy Shield Self-Certification in jeopardy without required operational updates and verification documentation in place.
Missed 2-month window. Fails to gain additional 9 month period. Can’t submit and be placed on the DOC list as Self-Certified until all required operational changes are in place.
Powering Privacy Compliance and Trust CONTACT US
US: 888.878.7830
www.truste.com
|
EU: +44 (0) 203 078 6495
www.truste.eu