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Joint Police ICT and National Enabling Programme Statement on European Court of Justice in the Schrems II case.

We welcome the initial guidance from the Information Commissioner’s Office (ICO) confirming that organisations should continue to use the Privacy Shield where it is already being relied upon. 

We will review any more substantive guidance from the ICO as it emerges and will consider the impact of that guidance on our international data transfers when it is published. In the meantime, we [The Police ICT Company & NEP] are reviewing all of our contracts to identify where the Privacy Shield and the SCCs are currently being used, and would advise forces to undertake a similar review in respect of their own contracts.  We are also preparing a strategic supplier engagement plan, so that we can work with our suppliers to respond to the judgment and the guidance which follows in due course. 

We will provide a further update once additional guidance is issued.

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