The Court of Justice of the European Union ruled in its "Schrems II" decision any company using standard contractual clauses must adopt additional safeguards to ensure an adequate level of protection for personal data transferred to the U.S. "Until now, commentators have seemed unsure as to what those safeguards might be or how they can address potentially irredeemable flaws in the U.S. surveillance system," writes ZwillGen's Marc Zwillinger, Mason Weisz and Kandi Parsons, who have a "proposed solution consisting of technical measures, supplemental clauses and exit strategies."
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