While the fines are relatively small, the data protection authority based in Hamburg, Germany, sent a message this week that the post-Safe Harbor honeymoon may be over. De Lege Data reports that the Hamburg DPA issued a press release (in German) saying it has reviewed the data transfers of 35 international firms recently and found that while most had created alternative mechanisms for transfer, three companies had not “switched to a valid alternative” to Safe Harbor within a half year of the Schrems judgment. Adobe, Punica and Unilever were all fined 11,000 euros or less, however, which the report notes is “significantly smaller than the theoretical maximum of 300,000 euros,” because they quickly implemented new mechanisms following contact from the Hamburg DPA.
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