The European Union’s (EU) new data protection framework, known as the General Data Protection Regulation (the “Regulation”), is, at bottom, a response to the astonishing evolution in online commerce.1 As a result, only one of the Regulation’s 91 articles specifically addresses the personal data of employees. This gap means U.S. multinational employers — especially those engaged in business-to-business (“B-to-B”) commerce — must carefully parse the Regulation to figure out how it applies to their management of a global workforce. To assist in that effort, this Insight describes 10 practical steps that U.S. multinationals can take towards satisfying those provisions of the Regulation with the greatest impact on managing a global workforce.
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