As we enter this last week of January, attention is focusing once again on whether EU and US representatives will be able to agree a “Safe Harbor 2″ data transfer regime to provide a replacement for the original struck down last year.  We understand that a key piece of the US compliance regime (the Judicial Redress Act) was delayed in being voted on in Senate last week, and that the vote may now take place on Thursday.  If so that just leaves precious few days before the European data privacy regulators meet on February 2nd to determine whether or not to start enforcement action against those entities who have not put in place a regime to legally allow data to transfer.

The next week will be an interesting time!