New FPF Study: More Than 200 European Companies are Participating in Key EU-US Data Transfer Mechanism


Co-Authored by: Daniel Neally & Jeremy Greenberg

EU Companies’ Participation in Privacy Shield Grew by More than One-Third Over the Past Year 

EU-US Privacy Shield Essential to Leading European Companies

From Major Employers such as Aldi and Dr. Oetker to Leading Technology Firms like CRISPR Therapeutics and Workwave, European Companies Depend on the EU-US Agreement

Privacy Shield Program Supports European Employment While Adding to Employee Data Protections – Nearly One-Third of Privacy Shield Companies Rely on the Framework to Transfer HR Information of European Staff

The Future of Privacy Forum conducted a study of the companies enrolled in the US-EU Privacy Shield program and determined that 202 European headquartered companies are active Privacy Shield participants. This is a 32% increase from last year’s total of 152 EU companies in the cross-border data transfer framework. These European firms rely on the program to transfer data to their US subsidiaries or to essential vendors that support their business needs. Nearly one-third of Privacy Shield companies use the mechanism to process human resources data – information that is crucial to employ, pay, and provide benefits to workers.

Thousands of major companies, many of which are headquartered or have offices in Europe, rely on the protections granted under the data transfer agreement. With dozens of new companies joining each week to retain and pay their employees or create new job opportunities in Europe, the Privacy Shield has become an integral data protection mechanism for European companies and the European marketplace as a whole.

Overall, FPF found that more than 5,000 companies have signed up for Privacy Shield since the program’s inception – more than 1,300 participants joined in the last year.

Leading EU companies that rely on Privacy Shield include:

–       ALDI, German grocery market chain

–       Alter Domus S.a.r.l., Luxembourg corporate and management services company

–       CRISPR Therapeutics, Swiss gene editing technology

–       Dr. August Oetker KG, German food, drink, household goods and industrial firm

–       EuroNext, European stock exchange

–       International Drug Development Institute SA, Belgian biostatistical and eClinical services company

–       LVMH (also known as Louis Vuitton), French luxury goods maker

–       Modern Times Group, Swedish digital media entertainment company

–       Omni Partners, British hedge fund

–       Randstad – Dutch human resources consultants

–       Workwave – Swedish software developer

FPF research also determined that more than 1,580 companies, nearly one-third of the total number analyzed, joined Privacy Shield to transfer their human resources data.

The research identified 202 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 202 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.

The Privacy Shield is a living and growing instrument, guaranteeing protection of the personal data of European consumers and employees as the backbone of fundamental rights protection within transatlantic commercial exchanges. Given the importance of this mechanism to supporting protection while enabling commerce on both sides of the Atlantic, we encourage careful review of the agreement this year by the European Commission and continued oversight and enforcement of the framework by authorities on both sides of the Atlantic.

The conclusions follow previous FPF studies, which highlighted similar increases in participation and reliance by EU firms on the Privacy Shield program.


  • FPF staff recorded a list of 4,818 active Privacy Shield companies as of June 2019 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.
  • 202 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].