On 29 June 2026, the US Supreme Court ruled that President Trump validly removed a commissioner from the Federal Trade Commission, the body which has primary oversight of the operation of the Data Privacy Framework (DPF). The concern in relation to this ruling is that if the President can remove commissioners without need for justification, the body may not be considered truly independent and therefore its ability to conduct independent oversight of the DPF is compromised.
The European Commission is currently analysing the decision, but this is at the very least a reminder of the importance of carefully mapping your data sharing, including international transfers, so that if there is a need to adapt your approach, you can do so quickly and efficiently.
If you would like any help with this, feel free to contact the team by emailing hello@hellodpo.com