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Corporate Counsel would do well to familiarize themselves with the ongoing process of reforms to the EU data protection rules due to their eventual compliance impact and because they constitute more than a simple upgrade to the existing rules. These reforms will affect not only U.S. businesses that currently have EU operations, but also any U.S. businesses without EU operations that are nevertheless active on the EU market and handle personal data. The aspect of the reforms that specifically deal with the rules on data transfers between the EU and the U.S. will also be affected, and have been the focus of particular EU political attention.
The proposed reforms to the EU data protection rules have advanced through the EU legislative pipeline with the March 2014 plenary vote by the European Parliament approving the amendments made at its committee level. Generally speaking, the Parliament has left the constituent elements of the original proposed reforms intact and has instead focused on qualifying a number of aspects and introducing some new elements.
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