Take-Aways (AI)
  • The EU Com­mis­si­on has post­po­ned the ade­qua­cy decis­i­on until after the ECJ ruling in the Schrems II case (July 16, 2020).
  • The eva­lua­ti­on report con­firms that the ECJ ruling could be essen­ti­al for ele­ments of the ade­qua­cy standard.
  • The Com­mis­si­on intends to con­ti­n­ue work on ade­qua­cy decis­i­ons with inter­na­tio­nal part­ners, inclu­ding pro­gress alre­a­dy made with Japan.
  • Tog­e­ther with the EDPB, the Com­mis­si­on is exami­ning the moder­nizati­on of other data trans­fer mecha­nisms such as stan­dard con­trac­tu­al clau­ses, cer­ti­fi­ca­ti­ons and codes of conduct.

The EU Com­mis­si­on has first on today plan­ned Ade­qua­cy decis­i­on post­po­ned. In con­nec­tion with the today published Eva­lua­ti­on report on the imple­men­ta­ti­on of the GDPR it can be infer­red that the ade­qua­cy decis­i­on will not be made befo­re the ECJ issues its judgment – expec­ted on July 16, 2020. in the mat­ter of Schrems II has felled:

Harnes­sing the full poten­ti­al of inter­na­tio­nal data trans­fersOver the past two years, the Commission’s inter­na­tio­nal enga­ge­ment on free and safe data trans­fers has yiel­ded important results. This inclu­des Japan, with which the EU now shares the world’s lar­gest area of free and safe data flows. The Com­mis­si­on will con­ti­n­ue its work on ade­qua­cywith its part­ners around the world. In addi­ti­on and in coope­ra­ti­on with the EDPB, the Com­mis­si­on is loo­king at moder­ni­s­ing other mecha­nisms for data trans­fers, inclu­ding Stan­dard Con­trac­tu­al Clau­ses, the most wide­ly used data trans­fer tool. The EDPB is working on spe­ci­fic gui­dance on the use of cer­ti­fi­ca­ti­on and codes of con­duct for trans­fer­ring data out­side of the EU, which need to be fina­li­sed as soon as pos­si­ble. Given the Euro­pean Court of Justi­ce may pro­vi­de cla­ri­fi­ca­ti­ons in a judgment to be deli­ver­ed on 16 July that could be rele­vant for cer­tain ele­ments of the ade­qua­cy stan­dard, the Com­mis­si­on will report sepa­ra­te­ly on the exi­sting ade­qua­cy decis­i­ons after the Court of Justi­ce has han­ded down its judgment.