Cross-border data transfer compliance
Cross-border data transfer compliance in Healthcare & Life Sciences is under simultaneous pressure from the U.S. Department of Health and Human Services Office for Civil Rights, the European Data Protection Board, and Japan's Personal Information Protection Commission, each applying sector-specific standards to patient data moving across jurisdictions. The European Data Protection Board's updated standard contractual clause guidance and the U.S. restrictions on transfers of sensitive health data to foreign adversary nations under the 2024 Department of Justice proposed rule have forced compliance teams to map vendor contracts and data processing agreements against obligations that do not align cleanly with one another. This page tracks material developments from all three jurisdictions as they land.
Watch
- DOJ proposed rule on bulk U.S. sensitive health data transfers to covered foreign countries
- EDPB Chapter V enforcement actions targeting health data processors using SCCs
- PIPC adequacy expectations for clinical trial data leaving Japan under APPI amendments
- HHS OCR guidance on cloud service provider agreements and cross-border PHI flows
Recent material activity in Healthcare & Life Sciences
Active monitoring in place across Healthcare & Life Sciences. Material developments related to cross-border data transfer compliance will appear here as they are published.