5. ... but it hasn't started yet
The European Commission jumped the gun in announcing Privacy Shield on Feb. 2, as many of the written promises from the U.S. on which the agreement depends did not arrive for another three weeks. On Feb. 29 the Commission published those documents, along with a draft "adequacy decision," the legal instrument by which Privacy Shield's provisions will be declared equivalent to the protections offered by EU law.
The draft adequacy decision is still open to challenge by the governments and data protection authorities of the EU's 28 member states, and must be reviewed annually to ensure that all parties are still respecting the undertakings on which it is founded. If they aren't, then in theory it can be suspended.
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