The European Court of Justice (ECJ) has announced that it will release its decision in the Schrems Safe Harbor case on Tuesday, October 6. It is highly unusual for the ECJ to issue a decision so quickly after publication of the Advocate General's opinion on a case. However, the ECJ seems to be expediting its decision process. (See the Wall Street Journal's summary of the usual process here.)
One way or another, the uncertainty generated last week by Advocate General Yves Bot's opinion invalidating Safe Harbor will come to an end soon. Last week we advised companies who rely on Safe Harbor for their EEA-to-US data transfers to get a contingency plan in place without delay. Now, it's urgent.
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