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“If the revision process currently undertaken by the European Commission does not lead to a positive outcome, then the Safe Harbor agreement should be suspended.” That was the message in a letter to Vice President and Commissioner for Justice Viviane Reding from Article 29 Working Party (WP) Chair Isabelle Falque-Pierrotin. The improvements made to modify Safe Harbor must be “valuable to the European Commission,” the letter states. Meanwhile, the WP has also issued an opinion on “making data processing legitimate.” The opinion states, “Beyond guidance on the practical interpretation and application of Article 7(f) under the current legal framework, it aims at formulating policy recommendations to assist policy makers as they consider changes to the current data protection legal framework.” A second WP opinion “analyses the effectiveness and limits of existing anonymisation techniques against the EU legal background of data protection and provides recommendations to handle these techniques by taking account of the residual risk of identification inherent in each of them.”
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