New FPF Study Documents More Than 150 European Companies Participating in the EU-US Data Transfer Mechanism


New FPF Study Documents More Than 150 European Companies Participating in the EU-US Data Transfer Mechanism
EU Companies’ Participation Grew by One Third Over the Past Year
By Jeremy Greenberg

Yesterday, the European Commission published its second annual review of the EU-U.S. Privacy Shield, finding that “the U.S. continues to ensure an adequate level of protection for personal data transferred under the Privacy Shield from the EU to participating companies in the U.S.” The decision preserves a key data transfer agreement, supporting transatlantic trade and ensuring meaningful privacy safeguards for consumers. It is also good news for EU employees and companies, many of whom rely on the agreement to retain and pay staff. The Commission’s review noted a key next step to support the Privacy Shield arrangement – urging the U.S. government to appoint a permanent Ombudsperson by the end of February 2019.

The Future of Privacy Forum conducted a study of the companies enrolled in the US-EU Privacy Shield program and determined that 152 European headquartered companies are active Privacy Shield Participants. This number is up from the 114 EU companies that were active Privacy Shield Participants last year. These European companies rely on the program to transfer data to their US subsidiaries or to essential vendors that support their business needs.

FPF also found that more than 3,700 companies have signed up for Privacy Shield – a nearly 70% increase in the number of participants from last year.

Leading EU companies that rely on Privacy Shield include:

  • ABB, Swiss electrical equipment company
  • Agfa, Belgian digital imaging and IT solutions company
  • CNH Industrial America, Dutch capital goods company
  • Fiat Chrysler, Italian global auto maker
  • HID Global, Swedish security company
  • Ingersoll-Rand, Irish globally diversified industrial company
  • Kodak Alaris, British photo retail and products company
  • Lidl Stiftung, German grocery market chain
  • Logitech, Swiss personal computer and mobile peripheral company
  • NCS Pearson, British education assessment and publishing company
  • P3, German management consultancy company
  • Reckitt Benckiser, British consumer goods company
  • RELX, British and Dutch information and analytics company
  • TE Connectivity, Swiss consumer electronics company
  • Telefónica, Spanish mobile network provider
  • WorkWave, Swedish software company

FPF research also determined that more than 1,150 companies, nearly a third of the total number analyzed, use Privacy Shield to process their human resources data. Inhibiting the flow of HR data between the US and EU would mean delays for EU citizens receiving their paychecks, or a decline in global hiring by US companies. Therefore, employees win when the Privacy Shield is maintained and grows.

The research identified 152 Privacy Shield companies headquartered or co-headquartered in Europe. This is a conservative estimate of companies that rely on the Privacy Shield framework – FPF staff did not include global companies that have major European offices but are headquartered elsewhere. The 152 companies include some of Europe’s largest and most innovative employers, doing business across a wide range of industries and countries. EU-headquartered firms and major EU offices of global firms depend on the Privacy Shield program so that their related US entities can effectively exchange data for research, to improve products, to pay employees and to serve customers. Given the importance of this mechanism to companies and consumers on both sides of the Atlantic, FPF is pleased that the Privacy Shield arrangement has been preserved and urges the U.S. government to quickly appoint a permanent Ombudsperson at the U.S. State Department.


  • FPF staff recorded a list of 3,703 active Privacy Shield companies as of September 2018 from
  • FPF staff performed a web search for each current company by name, checking the location of the company’s headquarters on a combination of public databases such as LinkedIn, CrunchBase, Bloomberg, and companies’ own websites.
  • A company that listed its headquarters in an EU member state or in Switzerland was counted as a match; companies that merely had a prominent EU office or were founded in an EU member state were not counted.
  • 152 total EU-headquartered companies were identified using this method.

For the full list of European companies in the Privacy Shield program, or to schedule an interview with Jeremy Greenberg, John Verdi, or Jules Polonetsky, email [email protected].