In 2008, we wrote about the then-current trend of outsourcing HIM functions to Europe and the compliance challenges associated with that activity. That article was published in the Journal of the American Health Information Management Association, and is accessible by clicking here. Our article referenced a “Safe Harbor” arrangement that was negotiated between the US Chamber of Commerce and the European Commission in 2000.
Unfortunately, fifteen years later, the European Court of Justice has now invalidated that arrangement, renewing the perils of these cross-ocean arrangements. You can read about the decision at http://www.nytimes.com/2015/10/07/technology/european-union-us-data-collection.html?_r=0