On 21 Nov 2018, at 9:03, Rupert Gallagher wrote:

On Wed, Nov 21, 2018 at 03:41, John Hardin <jhar...@impsec.org> wrote:
[...]
The US is not a signatory to the GDPR as far as I am aware, and I have
*no* legal presence outside the US.



The US signed a bilateral agreement with the EU:
https://www.privacyshield.gov/

It's widely misunderstood how hard it is for the US government to enforce the laws of other countries on US people and companies.

Participation in Privacy Shield is an entirely voluntary program and the only punishment for a self-certifying entity that claims to be complying is that if the FTC determines that they persist in non-compliance, they are removed from the list of complying entities and added to a list of persistent non-compliers. Beyond that, the only punishment would be if they continue to claim participation in Privacy Shield (i.e. simple fraud.)

There is no reason for anyone without a commercial presence in the EU or CH to be concerned with GDPR.

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