The Article 29 Working Party recently issued a statement regarding the CJEU Max Schrems Safe Harbor case. It announced that the European Union and the United States will have until the end of January 2016 to find a political, technical, or legal solution to the now invalidated Safe Harbor agreement for transfer of data from the E.U. to the U.S.

The Working Party noted, however, that such transfers that are still taking place under the Safe Harbor after the CJEU judgment are currently unlawful, and that EU DPAs (data protection authorities) may investigate particular cases (e.g., on the basis of complaints) and exercise their powers in order to protect individuals.

If by the end of January 2016 no solution has been found, the Working Party made clear that EU DPAs may then begin taking coordinated enforcement actions. The full statement is here.