EU’s Highest Court Upends Personal Data Transfers to the United States: Action Steps for U.S. Multinational Employers to Keep HR Data Transfers on Track

The Court of Justice of the European Union (“CJEU”), on July 16, 2020, invalidated the European Union-U.S. Privacy Shield Framework (“Privacy Shield”), which more than 5,300 U.S. organizations had relied on to lawfully transfer personal data from the European Union (“EU”) to the United States.1 While the same decision upheld