The Hamburg Commissioner for Data Protection and Freedom of Information published its observations on the proposed EU-U.S. Data Privacy Framework. The HmbBfDI advised data transfer impact assessments must follow the ruling by the Court of Justice of the European Union on lawful EU-U.S. transfers until the proposed DPF is finalized. The regulator also said the U.S. executive order to stand up the DPF "deserves a well-founded, open-ended examination" and "actual application" of provisions for proportionality and the Data Protection Review Court will be closely monitored.