October has been a busy month for Data Protection Authorities in the EU. Following the Court of Justice of the European Union’s judgment in Maximillian Schrems v Data Protection Commissioner (C-362-14) on 6 October, uncertainty ruled. Businesses and DPAs alike struggled to come to terms with the implications of the invalidation of Safe Harbor. This week, European Justice Commissioner Vera Jourova stated that an agreement in principle had been reached with the United States on a new trans-Atlantic data transfer pact, dubbed “Safe Harbor 2.0” by some. But what should businesses be doing in the meantime?

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