The draft document for ‘Safe Harbor 2.0’ was released on March 2, and is pending review and approval by the EU Article 29 Working Party by the end of March (sure).  Sidley Austin’s Data Matters blog covers it well.  In summary, the new framework is ‘significantly different’ from Safe Harbor 1.0 so companies must re-certify to “ensure a level of protection of personal data that is essentially equivalent to the one guaranteed by the basic principles laid down in Directive 95/46.”  Access rights, liability and provisions for securing personal data are all more stringent.

Bring on the ombudsperson!!!