On October 6, 2015, in a landmark ruling by the European Court of Justice

(ECJ) in Maximillian Schrems v. Data Protection Commissioner (C-

362/14), the ECJ declared invalid the Safe Harbor framework that has

streamlined the transfer of personal data from Europe to the United States

since 2000. The decision makes it prudent for any company that relies on

the Safe Harbor framework to reevaluate its data transfer programs and

their legality.