My company is an Internet company based in the U.S. Does my company need to comply with the EU safe harbor framework?
While the law is unclear as to what types of companies should become safe harbor compliant, our advice is to consider the following scenarios: • Internet companies whose brand is global in nature are likely to be accessed by European citizens and should comply with the safe harbor framework. • Internet companies that are targeting European citizens through media and advertisement should comply with the safe harbor framework because they are likely to receive information about European citizens. At a minimum in either scenario, joining a safe harbor program ensures that you are handling European data appropriately. You should also check with your legal counsel.