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The policy commits Thomson Reuters to refer unresolved DPF-related complaints from EU, UK, and Swiss individuals to JAMS for alternative dispute resolution at no cost to the complainant, with the FTC confirmed as the governing enforcement authority for DPF compliance.
This analysis describes what Thomson Reuters's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes the dispute resolution pathway for EU, UK, and Swiss individuals whose personal data is transferred to the United States under the DPF, including a binding arbitration option as a last resort mechanism under DPF Annex I, and confirms FTC enforcement jurisdiction over Thomson Reuters' DPF adherence.
Under this clause, EU, UK, and Swiss individuals with unresolved DPF complaints may file with JAMS for free alternative dispute resolution, and retain the right to invoke binding arbitration under DPF Annex I as a further remedy if other mechanisms fail.
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"In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.Excerpt from Thomson Reuters's Privacy
1) REGULATORY LANDSCAPE: The EU-U.S. Data Privacy Framework was established by the European Commission's adequacy decision of July 2023. DPF certification subjects participating entities to FTC enforcement authority and requires cooperation with EU data protection authorities for HR data complaints. JAMS is the designated independent recourse mechanism under the DPF. The DPF Annex I binding arbitration mechanism provides individual recourse as a last resort. The Swiss-U.S. DPF operates under Swiss Federal Data Protection Commissioner oversight. 2) GOVERNANCE EXPOSURE: Medium. DPF certification creates ongoing compliance obligations including annual recertification, adherence to DPF Principles including the Accountability for Onward Transfer Principle, and cooperation with DPA panels for HR data complaints. Non-compliance with DPF Principles can result in FTC enforcement action and loss of certification. 3) JURISDICTION FLAGS: EU member state supervisory authorities retain jurisdiction over HR data complaints in the employment context. The UK ICO cooperates with Thomson Reuters under the UK Extension. Swiss Federal Data Protection Commissioner oversight applies to Swiss-U.S. DPF transfers. The adequacy of the EU-U.S. DPF has been subject to legal challenge and its continued validity depends on ongoing political and legal developments. 4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers relying on Thomson Reuters' DPF certification as the transfer mechanism for EU, UK, or Swiss employee or user data in their own data processing agreements should verify that the specific Thomson Reuters entities processing their data are included in the certified self-certification list. The Accountability for Onward Transfer Principle means Thomson Reuters remains responsible for onward transfers to sub-processors. 5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that Thomson Reuters' DPF self-certification is current and covers all relevant U.S. entities and data categories. Data processing agreements should specify DPF certification as the transfer mechanism and include provisions addressing what occurs if DPF adequacy is invalidated. Monitoring the legal status of the EU-U.S. DPF adequacy decision is advisable given its litigation history.
This provision establishes the dispute resolution pathway for EU, UK, and Swiss individuals whose personal data is transferred to the United States under the DPF, including a binding arbitration option as a last resort mechanism under DPF Annex I, and confirms FTC enforcement jurisdiction over Thomson Reuters' DPF adherence.
Under this clause, EU, UK, and Swiss individuals with unresolved DPF complaints may file with JAMS for free alternative dispute resolution, and retain the right to invoke binding arbitration under DPF Annex I as a further remedy if other mechanisms fail.
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