According to these sources (see here in Spanish and here in English), in November 2015, the Agencia Española de Proteccion de Datós (AEPD) sent a notice to all Spanish companies known to transfer data to third countries.
The AEDP asked those companies to cease international data transfers after the European Court of Justice held the Safe Harbour invalid (C-362/14, Maximilian Schrems v. Data Protection Commissioner). For those companies that do not intend to quit such transfers, the AEDP suggests the use of Model Contract Clauses, as an alternative mechanisms to the Safe Harbor (see here for more information).
The deadline set forth by the AEPD is January 29, 2016, in line with the timeline set by WP29 in its post-Schrems statement.
More information on C-362-14 is available at http://www.technethics.com…
For more information, Francesca Giannoni-Crystal