IAPP Westin Fellow Anna Myers, CIPP/US, offers this study examining the U.S. Federal Trade Commission’s Safe Harbor enforcement record for practices and trends that may inform its efforts under the new Privacy Shield. Looking at the number of the FTC’s privacy cases through the years, and specifically substantive versus technical violations, the report concludes that while the FTC’s enforcement of Safe Harbor was limited, so was European participation in providing referrals and forwarding complaints.