On 23 October 2015, the Portuguese Data Protection Authority (the “CNPD”) issued a statement (available in Portuguese only) outlining its position on transfers of personal data to the U.S. following the Schrems judgement. Businesses that are subject to Portuguese data protection law and engage in transatlantic data transfers would be prudent to assess and adapt those data transfers in light of the statement.What Does The CNPD Say?The CNPD makes the following key statements:Data flows under…