Hogan Lovells put together a useful, color-coded table that analyzes the key messages put out by each DPA and evaluates their stances on the legality of data transfers to the U.S., as well as some other countries, following the ruling.
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The IAPP is also crowdsourcing and curating a "Schrems II" resource page with links to each DPA's statements and guidance on the ruling that will be updated as more of these resources become available.
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DPAs across the continent have offered strikingly disparate assessments of what the ruling means for EU-U.S. data transfers that rely on SCCs.
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Another group of DPAs, which includes Ireland's DPC and Germany's BfDI, have taken what could be described as an intermediary position between these two points, advising companies that they may continue to rely on SCCs but must heed the risks inherent in the mechanism and undertake additional assessments to determine if these transfer are lawful.[
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