(Editor's note: This brief has been updated to reflect that the German state DPA released the below guidance on "Schrems II." It was initially reported Germany's BfDI released the guidance.)

The Baden-Württemberg Commissioner for Data Protection and Freedom of Information released guidance on data transfers following the Court of Justice of the European Union’s ruling in "Schrems II." The LfDI recommends companies immediately take stock of data transferred to third countries, determine whether there is an adequacy decision for that country, and verify if standard contractual clauses can be used. The authority is aware the ruling “may impose extreme burdens on individual companies” and will monitor developments.
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