Spain’s Data Protection Authority, the Agencia Española de Proteccion de Datós (‘AEPD’), has issued a deadline of 29 January 2016, for the implementation of alternative mechanisms to Safe Harbor.

By letter dated 3 November 2015, the AEPD imposed the deadline on all companies operating in Spain that had previously notified it of personal data transfers to the United States which were based on the recipient’s Safe Harbor certification.  The letter requires companies in Spain to inform the AEPD of the mechanism(s) they have implemented to ensure the “adequate protection” of personal data which is transferred to the United States.
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