In a piece for Law360, Sidley Austin Partner Alan Charles Raul laid out text companies can use as a supplemental measure to inform U.S. intelligence agencies that data transfers conducted via standard contractual clauses are exempt from targeting. Raul wrote the communication he outlined could be used as part of the self-assessment obligations businesses are required to undertake following the "Schrems II" ruling. Raul added those obligations can be enhanced by the Foreign Intelligence Surveillance Act's Section 702 "prohibition against targeting U.S. person communications."
Full Story