EU DPA Fee

About

The United States Council for International Business (USCIB) advances the global interests of American business both at home and abroad.  It is the American affiliate of the International Chamber of Commerce (ICC), the Business and Industry Advisory Committee (BIAC) to the OECD, and the International Organisation of Employers (IOE).  As such, it has agreed to act as a trusted third party on behalf of the European Union (EU) Data Protection Authorities.

Background

The EU-U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from EU member countries to companies in the United States, requires that participating U.S. companies have in place appropriate independent recourse mechanism/s (IRMs) for dispute resolution.  Any company may choose the EU Data Protection Authorities (EU DPAs) to serve as an IRM for dispute resolution; however, any company that wishes to cover ‘human resources data’ (i.e., personal information about employees, past or present, collected in the context of the employment relationship) under its Privacy Shield self-certification must use the EU DPAs as the IRM for that category of data.

For all companies who have chosen the EU DPAs to serve as an IRM for dispute resolution (i.e., have agreed to participate in the dispute resolution procedures of the panel established by the EU DPAs to resolve disputes pursuant to the Privacy Shield Principles), an annual fee must be paid to United States Council for International Business in the amount of US $50.00 to cover the operating costs of the EU DPAs’ dispute resolution panel.

Payment to USCIB

Payment of the aforementioned fee to USCIB by a company does not obviate the need for that company to self-certify the company’s commitment to the EU-U.S. Privacy Shield Framework.  Information concerning the self-certification process under the Privacy Shield program administered by the U.S. Department of Commerce is available on the Department’s Privacy Shield website: https://www.privacyshield.gov/.  For detailed questions concerning the EU-U.S. Privacy Shield Framework, please contact the Department’s Privacy Shield Team at https://www.privacyshield.gov/assistance.