Following a decision of the CJEU (see the following from our data protection team on this) the treatment of data sent to the United States will no longer be compliant with European data protection ‎law simply by using the “safe harbour” exemption. This means that pension scheme data which is held in and or transferred via the United States (which can often be the case for outsourced administration) will need to be reviewed to ensure that the employer and trustees are not liable for fines if this exemption has been used.