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The ULD, the data protection authority for the German state of Schleswig-Holstein, has taken the step that many have predicted and issued a position paper that follows the ECJ's logic to declare model contract clauses, even consent, to likely be invalid ways of transferring data to the U.S. "The ULD specifically recommends that companies using standard model contracts cancel them with their U.S. partners and do a complete review of data transfers, consulting with the ULD in basically every instance," Sam Pfeifle writes in this exclusive for The Privacy Advisor, asking, "Will other data protection authorities follow suit?” Meanwhile, reached out to data protection authorities (DPAs) in Berlin and Bremen, and both confirmed they share the same view as the ULD.
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