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With a tender kiss and a cuddly teddy bear, Larry Birkhead shared an emotional moment with his daughter Dannielynn yesterday, before the two took a private jet out of the Bahamas.
Shortly after this photo was taken, daddy and daughter landed in Birkhead's homestate of Kentucky, where Dannielynn is getting to know some of her extended family.
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THERE'S A big controversy in the game at the moment about who should – or shouldn't – be eligible to play for England this year.
We have now got an Australian coach, Wayne Bennett, who works in the NRL and it seems he is keen on getting players from there to play for England in this year's Four Nations and the 2017 World Cup.
Tony Smith, the Warrington coach, has come out and said he isn't sure that is the right way to go about things.
I can see where he is coming from and I share his concerns.
It has happened in the past. We've had overseas players who qualify for England through their grandparents and Maurie Fa'asavalu and Rangi Chase got in because they'd lived here a certain amount of time.
But now it looks like players who don't really have a connection with England are being offered the chance and that can't be right.
Speaking as an Englishman, who is proud to have played for his country, I want to keep it English.
The players on duty for the national team have to be there for the right reasons, because they want to play for England.
There's lots of rumours around at the moment about Aussie-based players being asked if they are interested or putting their hand up and I think the sooner it's nipped in the bud and we find out exactly what is happening, the better it will be for everybody.
We all want to know what they are looking for and who is eligible.
The most disappointing thing will be if English players, who are playing well for their club, miss out.
We have got players who are in form and can do a job for the national team and it will be wrong if they don't get the opportunity to feature on the biggest stage.
There's a plethora of young English players coming through and playing to a decent standard and it will be a shame if they miss out on playing for England at the end of the year because an Aussie-based player, who might not be that bothered about pulling the jersey on, gets the nod first.
You might say that's the way things happen nowadays, but that doesn't make it right.
When I was coming through Jamie Peacock was in the England squad and he was really patriotic about wanting to play for England.
That rubbed off on everybody in the camp.
As a kid I used to watch England or Great Britain playing Test matches on the BBC and it was a dream to do that one day.
Pulling the shirt on for the first time and singing the national anthem was a highlight of my career.
It doesn't sit right with me that Aussies can decide for whatever reason they don't want to play for Australia, so they'll put their hand up for England instead.
As an Englishman I would prefer to see English born and bred players in there.
I think we've got enough of those to pick a squad from and it will devalue it if we finally beat Australia in a series with a team full of Australians.
We don't need to go down that route.
There's a World Cup next year and I think we can send a strong squad over to that with a real chance of getting to the final and winning it.
The eligibility rules need sorting out.
International rugby league is really important, but players swapping from one country to another could make it a bit of a laughing stock.
Once you play for one country, you shouldn't be allowed to change your mind and represent another.
We see it happening with players from the South Sea Islands, who switch allegiances to Australia.
I think that's a shame because it weakens their home nation and it's not as if Australia are short of players themselves.
I am proud to have played for England and I'd like to think I might get the chance again, but that's not something that's high on my agenda.
I've had a tough year with injuries and it hasn't been the best season for the team.
At the moment my priority is on getting fit, staying fit and playing well for Rhinos.
We have got seven crucial games coming up, beginning at Featherstone tomorrow.
We have to be switched on and all my focus is on helping us get through this tough period, then whatever comes off that is a bonus.

subset: commoncrawl


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ECOSOC established ISAR in 1982 as a body that allows for 34 formal ISAR members to serve three-year terms. These 34 members include nine African, seven Asian, six Latin American, three Eastern European, and nine Western European and other States. Member States may appoint any expert from their country as their nominated representative in ISAR. Representatives typically come from the Ministry responsible for accounting and reporting issues, from securities and financial regulatory agencies, or from national accounting associations.
Note that all member countries of the United Nations are able to send representatives to ISAR sessions, and that ISAR membership carries no financial obligations
Benefits of formal membership
Formal members of ISAR would be given a priority role in participating in ISAR annual sessions (including bureau activities such as chairmanship), consultative group and ad hoc meetings, workshops and training events. During the intersessional period of ISAR, members would have the opportunity to provide inputs in the preparations of the annual ISAR session, the direction of its activities, and ways to enhance its outreach.
Application Process
Member States interested in formal membership should contact their Permanent Mission in New York or the Ministry of Foreign Affairs in their capital and request them to submit the candidacy for election to ISAR. The letter requesting membership needs to be addressed to the Chair of the relevant regional group for the month, who are listed in the UN Journal, with copy to the ECOSOC secretariat in New York and the ISAR secretariat in Geneva.
Focal Points:
Note that it is not necessary to delegate the expert that will represent the country in its formal membership with the application. This information can be communicated after the election in the form of a note verbale to the ISAR secretariat in Geneva.
The ISAR secretariat in Geneva remains available to provide up-to-date information on the relevant contacts for ISAR membership application, as well as more additional information about ISAR's impact and agenda.
Current members
United Nations Conference on Trade and Development
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It's campaign sign theft season.
For the second time in the past three months, signs promoting candidates in the Menlo Park City Council race have been pilfered. At roughly 9 a.m. Oct. 21, Councilwoman Catherine Carlton reported that approximately 10 of her campaign signs were stolen from supporters' front yards, said police spokeswoman Nicole Acker, adding that the thefts weren't concentrated in any particular area of the city. The case has been suspended, due to a lack of witnesses or surveillance footage.
In mid-August, 12 of Councilman Ray Mueller's campaign signs were stolen from 10 residences between the 1200 and 1900 blocks of Santa Cruz Avenue, and portions of Rosefield Way, Cloud Avenue and Bellair Way. No arrests were made in that case. Mueller, Carlton and Cecilia Taylor are running for two open council seats on Nov. 8.
"This happens every campaign year, it just happens, this isn't something unusual," Acker said.
What is not so usual is somebody being identified as a suspect in the sign thefts, which is considered petty theft, a misdemeanor.
"I don't remember anybody being caught for stealing a sign," she said.
In October 2011, John Woodell, husband of Mayor Pro Tem Kirsten Keith, was accused of moving a campaign sign belonging to Menlo Park Fire Protection District board member Virginia Chang Kiraly after Woodell's cellphone was found near a fallen sign. No arrest was ever made, and a 4-year-long defamation lawsuit brought by Woodell against Chang Kiraly was ultimately tossed by a state appeals court this past January.


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Microtel Inns Fayette properties are listed below. Search for cheap and discount Microtel Inns hotel rates in Fayette, AL for your group or personal travels. We list the best Microtel Inns Fayette hotels + motels so you can review the Fayette Microtel Inns hotel list below to find the perfect place.
This site will also list discounted Fayette, AL hotels & lodging that get similar quality scores of a Microtel Inns.
How should we direct your call?


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The Rochester, as with Empire East giving, exhibits an array of thrilling features. The amenity space includes a swimming pool area complex, basketball and tennis courtroom, play ground, running route, fitness center, 100-seater multi-purpose corridor, mini-bar and Wi-Fi empowered club house. You aren't restricted to conventional residences within the Rochester housing market. There are many other kinds of residence obtainable in the town which you'll think about on your home-search. Usually open up your self as much as choices simply because you'll discover that with lots of options, understanding what home to select will be better.
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Monday, November 1, 2010
End of An Era
Please note that as of yesterday, I will no longer be adding new posts to this blog. The archive remains, with nearly 1,000 vegan recipes for you to enjoy, and I hope you will continue to do so! In the meantime, I'll be blogging in a slightly new format and style over www.veganchronicle.blogspot.com I look forward to seeing you there!
Posted by R Starr LeMaitre at 2:58 PM
1 comment:
- firstname.lastname@example.com said...
Oh I just found you! Too late, I suppose. From what I'm seeing so far, looks great. I wish you the best. Thanks for sharing.
- December 28, 2010 at 7:58 PM
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The Vegan Pantry
- Vegan yogurt - Whole Soy http://www.wholesoyco.com/
- Vegan milk - Silk http://www.silksoymilk.com/
- Vegan Feta - Sunergia http://www.sunergiasoyfoods.com/
- Vegan Cheese - Galaxy Foods http://www.galaxyfoods.com/
- Vegan Eggs - Ener-G http://www.ener-g.com/
- Vegan Butter - Earth Balance http://www.earthbalance.net/product.html


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Back to Basics?
A high-pitched bark wakes us from our slumber. It is Cheyenne letting us know once again that she needs us. Normally I wouldn't mind but at 1:30am, you have to be a little put out.
For the last week, the "wee one" in our house has been waking us up at 1:30am to go potty and poopy. Strange behavior it is. You see, both Labs go out around 10pm and don't have to go out again until at least 5:30am. So what's up with Cheyenne that she now has to go in the middle of the night?
It isn't that she is wide awake and wants to play or anything. As soon as she is done going to the bathroom, she trots right back into the house and straight to the back of the house and in her crate to return to sleep. No commands are given for her to settle down. She just wakes us, does what she has to do, and returns to her bed.
Originally I thought it was some treat we may have given that has upset her stomach. Of course, you can keep an eagle eye on Cheyenne and she will still eat something she shouldn't outside. (She is a Labrador Retriever after all!) So, I figured we would not give her any treats (other than her normal dog treat) and let this emergency middle of the night bathroom call run itself out. But, it is not running itself out after a whole week. So, now I have to wonder - did she truly get into something that is upsetting her tummy or has her body decided to put itself on a new (and annoying) bathroom schedule?
This leads me with a decision to make. Do I go back to basics and crate her during the night, like we did when she was a pup, so that we have control over slowly bringing her bathroom habits back to 5:30am or let nature run its course? Definitely a tough call... definitely something that needs a bit of thinking...
Wish us luck!
Labels: Lab Life, Lab Training


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Far Left TV Host Tavis Smiley: More Christians Than Muslims Blow Up People Every Single Day (Video)
Far left radio and TV host Tavis Smiley told Islamic expert and beauty Ayaan Hirsi Ali that more Christians than Muslims blow up people every single day.
Town Hall and FOX Nation reported:
The sad thing is that far left loons actually believe this crap.
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I think coming off of the holidays is always kinda hard. You've been going non stop for weeks and now it's the new year and you think you need to have it all together right away. I mean everyone else seems to have it all together. Well I'm here to tell you, I don't have it all together.
I am so not motivated to do anything outside the every day life right now, which is okay. I think it's a good time to just unwind, relax our brains and just do what we need to do and nothing more. I can't go from one thing to the next so quickly. I need a break in between.
I can't think about 30 days of organizing, or what books I want to read this year, or what curriculum I'm going to buy my kids next year, etc. (and all that totally appeals to me) but I'm just stepping back and letting each day come and each day go. No real plans or things thought out, just living (and homeschooling *smile*).
Speaking of just living, I had to show just how real I am on my Facebook page the other day.
This is our king size fitted sheet for our bed and this is how I folded it and put it in our linen closet. Didn't bother me one bit. *smile*
What I really loved was the fact that there were so many of you who totally confessed to doing the same thing. You all make me smile and I love ya!
Have a lovely day my friends.


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Marshall Code 50 by CJ Mastering
I have been playing through this amp for the past 3 months and now i have a good idea of how it matches up to other amps i played through. I have the 50w code with a 12" speaker, and they also come in 25w and 100w. The price i paid for it was $249.00 and i bought the foot pedal for an additional $60.
What i love about this amp is that it has all the sounds form all of the great marshal amps that were previously made and it also has modulation, delay and reverb effects and also a built in tuner as well. So for a fraction of what it would have cost me, i can get all the marshal sounds i grew up loving in this one combo amp.
It also comes with a smart phone/tablet/PC app that can control the effects and patches. Its pretty cool to use.
It just a great all in one combo amp. if you love the vintage marshal sounds, (the crunch and clean ones), you'll love this amp.
CJ Jacobson
Online Audio Mastering Studio - Award Winning Mixing and Mastering


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Remedy Meeting Times
Sunday nights 9-12th grade will gather for worship that is about being inspired by who God is and striving to grow in our desire to follow him fully. Doors open at 6:00 p.m. and we will finish by 7:30 p.m., but you are free to hang out until 8:00 p.m.
Sunday Mornings 6th-12th grade will meet in the Youth Area on the West Campus from 10:00 a.m. - 11:00 a.m. for a great time of digging deeper into God's Word. There are various groups that meet during that hour that are divided according to age and gender.
Monday Nights 9-12th grade will meet for Bible Study from 6:00 p.m. - 7:30 p.m.
There may be a separate registration information, forms, etc. for specific events and activities. See the info provided on the Events/Registration tab to ensure you have all that you need.
Stay in touch by joining the Remedy Youth Facebook group, liking the Facebook page or by following us on twitter @remedyyouth.


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When I look at the whole world through the lens of my eyes, there's a tremendous gap and is now spreading and opposition that lurks. Our paths have been shifted by the constraints of the call for immigration restrictions, the city where I live and its particular consequences: mainly technological changes.
The new wave of technology is a potent agent of change since it can alter a city's place advantage turning a miserable place into an excellent one. Our private beliefs and principles, diverse standpoints including intolerance are challenges of a global setting. There's demand for a heavy immersion within distinct cultures to understand their worth and unique circumstance. Knowing other cultures join the world and profoundly can link the dots between nations and emphasize meaningful differences between cultures that impact.
The global community has an enormous opportunity on a regular basis especially our generation when compared with past cultures. . Consequently, this calls for a more culturally congruent feeling when addressing social circumstance. Every country has its distinguishing features, history, and political facts and as a result, accessibility to associations around the whole world is required.
From my view, many nations do not have similar values and infrastructure that improve international functionality regarding income per capita. I believe the worldwide community can achieve similar aims and policies that deepen universal link, even though every country has a diverse group of experiences. Furthermore, it would not be argued against by any nation. Instead, each economy should assert that its aim would be to participate in a substantial worldwide investment that supports an international connection. In light of this, one nation cannot ever understand it since the acceleration of our connected world and its dynamic complex system.
Equally important is a country's standard of living and also the complete independence. Greater freedom means greater functionality. Freedom means liberty and diversity. When the global world is barrier free, folks achieve higher income levels. Both local and international impediments create extortion, bribery, and distortion which change every element of our global system. Moreover, the dearth of ethics proceeds to inflict high expense of illegal transactions in world market interaction.
In the same way, our lives are driven by fear that inhibits cooperation.
All things considered, challenges and the opportunities of our connected world is an ongoing procedure, and it plays a vital role in our current connections. In essence, in the event the disparity between the wealthy and poor is minimized, the larger the room for long run growth and sustainable international link.


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Thirty-two women knelt this evening in Bristol Cathedral for the laying on of hands by the Bishop and became the first women ordained as priests in the Church of England's 460 years.
The ordination of women, which seemed inevitable since it was found to be theologically unobjectionable by the General Synod of the Anglican Church in 1975, has prompted a bitter debate for almost 20 years.
The two decades are sometimes said to be the most divisive period in the church since Henry VIII established it and severed the nation's ties to the Church of Rome over Pope Clement VII's refusal to annul his marriage to Katharine of Aragon so that he could wed Anne Boleyn. And there are signs that the split has not ended. Priests Revert to Catholicism
Some 700 clergy members, some of them retired, have indicated an intention to convert to Roman Catholicism. So far only 35 priests have resigned, although 115 others have indicated they will do so by next January. There are 10,200 priests in the church altogether.
The 32 female deacons gathered in the historic cathedral in white robes today and arranged themselves in a rectangle around the Bishop, the Rt. Rev. Barry Rogerson. They answered the questions to test their faith and then the congregation followed the Bishop in silent prayer for them.Continue reading the main story
The Archbishops of Canterbury and York, Dr. George Carey and Dr. John Habgood, both of whom favor ordaining women, said that today's service was "a new beginning" that "marks the culmination of almost 20 years of formal debate and many more years of prayer and reflection."
The decision to allow ordination of women was not "undertaken lightly or hastily," they said in a joint statement, and although most believed the ordinations to be God's will, "others, of course, believe the move to be mistaken." They urged church members to show "generosity, tolerance, courtesy and loving patience with each other."
The Vatican reacted sharply to today's ordinations, even though they came as no surprise, reasserting its opposition to priesthood for women and saying that the Church of England's decision was a setback for reunion.
In a statement issued only hours before the ceremony in Bristol, the chief Vatican spokesman, Joaquin Navarro-Valls, said Pope John Paul II "had clearly and publicly affirmed that the ordination of women also constitutes a profound obstacle to every hope of reunion between the Catholic Church and the Anglican communion."
"This reunion is and remains a great hope, which this new obstacle makes more difficult," Mr. Navarro-Valls said, referring to talks between the Vatican and the Church of England on possible reunion that began shortly after the Second Vatican Council. Decade-Long Struggle
But these considerations did not seem to mar the occasion for the 32 women who became priests today, many of whom struggled for a decade or more for the right to participate in certain rites of the church and beginning Sunday, will be allowed to celebrate eucharist.
Jane Hayward, looking ahead to Sunday services, said she was very excited but very nervous.
"I'm too concerned with getting the service right," she said. "As we are the first, people will watch closely and those who are a bit against us will say, 'Ah, she's got it wrong, she can't do it.' "
Christina Rees, a member of the General Synod's laity who speaks for the Movement for the Ordination of Women, pronounced it a "a great day" as she was caught in a crowd outside the Bristol Cathedral. "I'm actually beginning to believe this is actually happening," she added with a laugh. Male-Only Parishes
The Church of England has attempted to accommodate die-hard "traditionalists" by establishing provisions for a diocese or a parish where female priests would not be allowed to minister. In the case of a diocese, it may be done by declaration of the bishop and in the case of a parish by a vote of the parochial church council. No such areas have been set up yet.
Through an "act of Synod," which has considerable moral authority even though it lacks the force of law, the church has also provided for three so-called flying priests, who will give pastoral care to those who refuse to accept it from female priests.
The church has also pledged that it will not discriminate, in either choosing priests or making senior promotions, against those who oppose female ordination.
Finally, it has provided compensation for priests who choose to resign, a deal that includes a three-year package averaging about $45,000 in place of salary, a $5,400 resettlement grant and various housing entitlements.
The attempt to keep people opposed to female priests within the fold by offering them something approaching a parallel church has raised fears among some church members of two schools, one that accepts women as priests and one implacably opposed. Earlier Ordination of Women
The ordination of women has become common in the Anglican Communion in other countries since the first woman, Florence Li Tim Oi, was ordained in the Portuguese colony of Macao in 1944, a time when there was shortage of male candidates because of the war.
There are now about 1,380 female priests in churches within the Anglican communion around the world. The Episcopal church in the United States as well as Anglican churches in Canada, Australia, New Zealand and other countries have had female priests and even bishops for years. The Presbyterian Church of Scotland also ordains women.
But opposition in the home church of international Anglicanism was fierce, with opponents arguing that Jesus would not have chosen all male apostles if he had wanted female priests. One priest in the Lincoln diocese compared female priests to witches and dogs. Another from Humberside came to Bristol today and placed an ad on a billboard reading "The Church of England murdered today."
Only two days ago the British High Court turned down an attempt by a priest to block the ordinations with a lawsuit arguing that the religious law allowing the ceremony was invalid.
The Vatican has encouraged Anglican clergymen, including those who are married, to convert and become priests in the Roman Catholic Church, issuing guidelines after meeting with a delegation of Catholic Bishops from England and Wales in December.
But officials within the Church of England say that the opposition is not as widespread as the few publicized cases would make it seem. They pointed out that the proposal for female ordination passed the General Synod in November 1992, by the required two-thirds majority, and that one poll showed that 90 percent of Britons support the move.
Among 53 bishops on the Synod, 13 voted against, but none have taken steps to prevent female priests from ministering in their own dioceses, a step that was agreed to to secure their reluctant cooperation. More than 1,000 women are expected to become priests this year.Continue reading the main story


text: Kitchen Fun Time #4 – Sushi Making! by BZMOMMY // November 3, 2013 // No Comments I had always thought that rolling a sushi (or maki) is a difficult task and I will never learn how to make my own sushi. However, I realised that I was so wrong! It was until I went to a... Continue reading →


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Hello ladies, I went for my first scan yesterday..was an internal one as I thought I was about 7/8 weeks
No baby was visible on screen.. Just a sac and a small strange shape, the doctor said it should have been a perfect circle?
I have had no pain, bleeding or even discharge.. They took blood to check my hormone level and it's very high!
I am due to go back to hospital for more blood test to see wether my hcg levels have risen or fallen
I'm confused and scared 😔😞 anyone had a positive end result to a similar situation? Xx


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Mandarin Oriental's pool area has a stunning array of color and dazzling views of The Strip, among its two lap pools, two whirpools and plunge pool.
Located on the eighth floor at Mandarin Oriental, the sophisticated and relaxing pool feels like you're in another world.
The décor of the pool area quickly grabs your attention. How often do you see cherry blossom-painted walls in cabanas, contemporary furniture in fun colors like yellow green, orange and gold as well as breathtaking views of neighboring hotels all in one spot? In addition, the overhead jazz music pairs perfectly with the serene atmosphere. And because of the location of the pool, it has one of the prettiest sunset views you'll ever see.
There are two lap pools, one Jacuzzi and one plunge pool, along with plenty of spots to unwind. These include lounge chairs (with or without umbrella shade) and even couches on elevated platforms. The pool offers 17 cabanas, each featuring a sectional couch with bright colored pillows, ceiling fans and misters.
The café is not to be missed. Diners can choose items like a tuna caprese salad (tomato, pesto, mozzarella, sashimi and Spanish olive oil) or even a refreshing cold gazpacho soup. Comfort food like freshly made chicken fingers with a signature sauce is also available. Vegetarians can savor the café's edamame falafel wrap with crinkle-cut sweet potato fries. The mochi and fruit dessert is not to be missed -- this beautifully presented plate includes three mochi flavors (lychee, mango and strawberry), kiwi, strawberries and star fruit topped with a fresh flower.
3730 S. Las Vegas Blvd., Las Vegas, NV 89109


text: ESSENTIALLY EQUIVALENT A comparison of the legal orders for privacy and data protection in the European Union and United States JANUARY 2016 datamatters.sidley.com PRIVACY SHIELD: Essentially Equivalent JULY 2016 datamatters.sidley.com No Legal Advice or Attorney-Client Relationship: This publication has been prepared by Sidley Austin LLP and affiliated partnerships (the "firm") for informational purposes and is not legal advice. This publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. You should not act upon this publication without seeking advice from a lawyer licensed in your own state or country. Do not send us confidential information until you speak with one of our lawyers and receive our authorization to send that information to us. Providing information to the firm (via e-mail links on this Web site or otherwise) will not create an attorney-client relationship in the absence of an express agreement by the firm to create such a relationship, and will not prevent the firm from representing someone else in connection with the matter in question or a related matter. No Warranties: This publication, and all information available on or accessed through this publication, is provided "as is." The firm makes no warranties, representations or claims of any kind concerning the information presented on or through this site. Copyright Notice: © 2016 Sidley Austin LLP and Affiliated Partnerships. All rights reserved. The firm claims a copyright in all proprietary and copyrightable text, graphics and computer code in this publication, the overall design of this publication, and the selection, arrangement and presentation of all materials on this publication, including information in the public domain. For further information regarding Sidley Austin, you may access our web site at www.sidley.com. Our web site contains address, phone and e-mail information for our offices and lawyers. The information presented in this publication may not reflect the most current legal developments, verdicts or settlements. The information may be changed, improved, or updated without notice. The firm is not responsible for any errors or omissions in the content of this publication or for damages arising from the use or performance of this publication under any circumstances. Attorney Advertising - For purposes of compliance with New York State Bar rules, our headquarters are Sidley Austin LLP, 787 Seventh Avenue, New York, NY 10019, 212 839 5300; One South Dearborn, Chicago, IL 60603, 312 853 7000; and 1501 K Street, N.W., Washington, D.C. 20005, 202 736 8000. Sidley Austin refers to Sidley Austin LLP and affiliated partnerships as explained at www.sidley.com/disclaimer. Prior results do not guarantee a similar outcome. datamatters.sidley.com THE PRIVACY SHIELD SATISFIES EU LAW REQUIREMENTS AND ADDRESSES CONCERNS THAT HAVE BEEN RAISED With the final Privacy Shield decision, the European Commission and United States Government have concluded several years of discussion and negotiation concerning the Safe Harbour framework and the new Privacy Shield. The effort and thought by negotiators, EU institutions, and stakeholders alike to reach this point reflect the importance of private life and data protection in EU society and the significance of data flows to transatlantic commerce and discourse. This labour has yielded a strong new framework that complies with EU law and sets a high standard for international data transfers. The Commission's Adequacy Decision of 12 July 2016 (C(2016)4176 final) is backed up by thorough examination and explanation of the safeguards provided by the US legal order and the added mechanisms of the Privacy Shield and responds to concerns by the Article 29 Working Party ("WP29"), European Data Protection Supervisor ("EDPS"), and European Parliament. As more fully detailed below, the Privacy Shield requirements far surpass those under Safe Harbour and ensure that EU residents whose data is transferred to the US receive protection essentially equivalent to what they receive in the EU. SUMMARY The Privacy Shield framework reflects strong political consensus on the shared importance of maintaining transatlantic data flows. This is a premise on which the Commission, the WP29, the EDPS, the Parliament, and the Member States all have concurred. The "many improvements" strengthening principles, administration, and oversight make protection of data under the Privacy Shield essentially equivalent. Generalised assertions that the Privacy Shield differs little from Safe Harbour have no basis in the actual operation of the framework. The Privacy Shield and robust changes to US laws since 2000 cover all 13 recommendations made by the Commission in 2013, and clearly render the new framework "adequate" under EU law. The major points of concern raised about the Privacy Shield are addressed by the final framework. The final Commission Decision clarifies numerous aspects of the Privacy Shield. In particular, it shows more specifically how US laws and the Privacy Shield address safeguards for national security surveillance consistently with CJEU and ECtHR jurisprudence and how the Ombudsperson will enlarge avenues of redress; makes data deletion explicit within the Data Integrity and Purpose Limitation Principle; clarifies onward transfer obligations; and takes steps to address automated processing. 2 datamatters.sidley.com The Privacy Shield framework reflects strong political consensus on the shared importance of maintaining transatlantic data flows. The Commission's 29 February 2016 Communication accompanying the Privacy Shield framework1 affirms the importance of data flows to the ties between the United States and the European Union : "[t]he transfer and exchange of personal data is an essential component underpinning the close links between the [EU] and the [US] in the commercial area as well as in the law enforcement sector". Each reviewing body acknowledges this premise. In its 13 April 2016 Opinion 01/2016 on the draft EU-U.S. Privacy Shield ("Opinion WP238"),2 the WP29 agreed notwithstanding its concerns: "Given the amount of data transfers that take place between the EU and the U.S. on a daily basis, which the WP29 recognises is a vital part of the economy on both sides of the Atlantic, legal clarity is needed sooner rather than later." Similarly, the EDPS recognised "the value, in the era of global, instantaneous and unpredictable data flows, of a sustainable frame for commercial transfers of data between the EU and the U.S., which represent the biggest trading partnership in the world".3 The 26 May 2016 European Parliament resolution on the Privacy Shield notes that "cross-border data flows between the United States and Europe are the highest in the world" and are "an essential component underpinning the close links between the [EU] and the [US] in commercial activities and in the law enforcement sector".4 As former Swedish Prime Minister Carl Bildt and former US Ambassador to the EU William Kennard wrote, "Data privacy has been a difficult issue across the Atlantic, but abandoning the privacy shield would cause huge disruptions not only in transatlantic commerce, research, and investment but also within the EU itself".5 1 http://ec.europa.eu/justice/data-protection/files/privacy-shield-adequacy-communication_en.pdf. 2 WP29 13 April 2016, Opinion 01/2016 on the EU-U.S. Privacy Shield draft adequacy decision issued, WP 238, http://ec.europa.eu/justice/data-protection/article-29/documentation/opinionrecommendation/files/2016/wp238_en.pdf, page 12 (para. 1.2). 3 EDPS 30 May 2016, Opinion 4/2016, Opinion on the EU-U.S. Privacy Shield draft adequacy decision, https://secure.edps.europa.eu/EDPSWEB/webdav/site/mySite/shared/Documents/Consultation/O pinions/2016/16-05-30_Privacy_Shield_EN.pdf, page 2 ("EDPS Opinion"). 4 Document P8_TA-PROV(2016)0233, European Parliament resolution of 26 May 2016 on transatlantic data flows (2016/2727(RSP)) http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+MOTION+B8-2016- 0623+0+DOC+PDF+V0//EN, resolution 2 ("Parliament Resolution"). 5 "Obama and Merkel: a chance to make history in Hanover," Politico (23 April 2016). 3 datamatters.sidley.com The Privacy Shield Principles, Oversight by the EU and US Governments and Data Protection Authorities, and Remedies Far Surpass What Was Required under Safe Harbour. The Privacy Shield introduces numerous measures to address any differences between levels of privacy and data protection in the EU and the US. The WP29 noted "significant improvements brought by the Privacy Shield compared to the Safe Harbour decision" and acknowledged that "many of the shortcomings of the Safe Harbour … have been addressed by the negotiators".6 The European Parliament resolution similarly welcomed "substantial improvements in the Privacy Shield compared to the Safe Harbour decision ...".7 In its 27 November 2013 Communication on the Functioning of the Safe Harbour from the perspective of EU Citizens and Companies Established in the EU (the "2013 Safe Harbour Communication")8 , the Commission framed 13 recommendations to address issues identified in the Commission's review. The Privacy Shield responds to all 13 of these recommendations. The responses in the Privacy Shield to the most salient concerns are addressed below. 1. Because the promises that companies in the US make are legally enforceable, the Privacy Shield significantly strengthens protection by requiring additional information under the Notice Principle. Annex II, containing the Principles and Supplemental Principles issued by the Commerce Department, sets out the obligations that companies accept by subscribing to the Privacy Shield. The new framework requires much greater detail in the notices and disclosures that subscribing companies must provide to data subjects. In particular, the expanded Notice Principle (pages 19-20) requires an explicit statement of a company's commitment to the Privacy Shield Principles, the types of personal data it collects, the type or identity of third parties to which such personal data is disclosed, and statements explaining the company's liability for improper onward transfers, as well as more detailed information about the enforceability of the Principles and means available for data subjects to seek redress. As the Commission states, although participation in the Privacy Shield is voluntary "effective compliance with the Principles is compulsory"9 because, as explained in the letter from the Chairwoman of the US Federal Trade Commission ("FTC") in Annex IV, the promises that companies make in their privacy policies and other public statements are legally binding and enforceable. 6 WP238, page 2. 7 Para. I.1. 8 http://ec.europa.eu/justice/data-protection/files/com_2013_847_en.pdf 9 Decision, recital 26. 4 datamatters.sidley.com The additional specific statements required under the Notice Principle clarify expectations for data controllers and data subjects alike and strengthen the ability to enforce Privacy Shield Principles. The 2013 Safe Harbour Communication found that "[l]ack of transparency by companies in the US renders Federal Trade Commission oversight more difficult and undermines the effectiveness of enforcement". The increase in transparency required by the Privacy Shield will facilitate oversight and enhance the effectiveness of enforcement. 2. The Privacy Shield Principles add new accountability for onward transfers by requiring specific steps to ensure that third-party controllers and processors use transferred personal data only for limited and specified purposes. The 2013 Safe Harbour Communication identified onward transfers to third parties as a concern in light of the growth of data flows and cloud computing. The Safe Harbour framework generally allowed transfers to the third parties that subscribed to Safe Harbour and shifted responsibility for compliance to such third parties. A 10 April 2014 letter from the Article 29 Working Party to Commissioner Reding10 recommended a specific accountability principle for onward transfers. The Privacy Shield explicitly incorporates such a principle with a new Accountability for Onward Transfer Principle (page 21), eliminating any shift in responsibility and requiring the subscribing company to contract with third party controllers and take steps (that may include contracts) to ensure that third-party agents process data in ways consistent with the subscribing company's obligations. In response to the WP29's concerns in the WP238 about onward transfers to third countries, the final framework includes an obligation on the part of these third parties to notify the subscribing company if they determine they become unable to maintain the required level of protection. 3. The Privacy Shield ensures much stronger administration and enforcement by increasing involvement of DPAs in the administration of the framework, expanding responsibilities of the US Department of Commerce, adding referral mechanisms, and strengthening the annual review process. The 2013 Safe Harbour Communication traced a history of concerns with the vigour of Safe Harbour enforcement beginning in 2004 and escalating from 2009- 13. Concerns included missing privacy policies among Safe Harbour companies, companies on the US Commerce Department Safe Harbour list that failed to maintain their certifications, and subscriber non-compliance with Safe Harbour principles as well as procedures. In response, the Commerce Department stepped up its policing of Safe Harbour certifications and the public list of certified 10 http://ec.europa.eu/justice/data-protection/article-29/documentation/otherdocument/files/2014/20140410_wp29_to_ec_on_sh_recommendations.pdf 5 datamatters.sidley.com companies, and improved its Safe Harbour website. In 2009, the FTC brought its first case alleging unfair or deceptive practices or acts stemming from violation of Safe Harbour commitments and has brought at least 23 more cases since then. (See Annex IV). The Privacy Shield incorporates these improvements and details numerous additional ones to reinforce oversight and enforcement. Annex I to the Privacy Shield, the commitments by the Commerce Department as augmented in the final version, reflects that the Commerce Department has increased resources dedicated to, among other responsibilities: • verifying that company self-certifications are complete (including a privacy policy that commits to the Privacy Shield Principles and the designation of recourse mechanisms of regulatory bodies) and, as recommended by WP29, verifying that these policies conform to the Principles11 (pages 6-7); • conducting periodic compliance reviews, including the "ongoing ex officio reviews" recommended by WP29 and EDPS12 (page 9); • keeping the Privacy Shield list up-to-date by removing companies that withdraw, fail to re-certify, or persistently fail to comply, and check that such companies continue to apply the Privacy Shield Principles to any information they are able to retain (pages 7-8); • maintaining a public listing of companies removed from the Privacy Shield list, with the reasons for their removal and (also as recommended by WP2913) monitoring these companies' compliance with requirements to return or delete data (page 17); and • referring cases of abuse of the Privacy Shield certification or other false claims to the FTC or other agencies (page 17). Annex I summarizing the commitments of the Commerce Department sets out what the Parliament Resolution welcomed as "the prominent role" given to DPAs in monitoring the Privacy Shield framework. Their expanded role is reflected in numerous ways: "interested DPAs" can participate in the annual review and raise the full range of issues including enforcement, changes of law, and information disclosed by the US Intelligence Community (page 10); and the WP29 will have a dedicated point of contact in the Commerce Department to refer complaints of non-compliance, coordinate on compliance reviews, and share information concerning participating organizations and material for use on DPA websites (page 9). DPAs also will act as conduits for requests to the Ombudsperson by EU individuals concerning government surveillance (Annex III (A), pages 53-54) . 11 WP238, page 28. 12 WP238, page 14; EPDS Opinion page 12. 13 WP238, page 29. 6 datamatters.sidley.com In addition, the Supplemental Principles in Annex II require companies to cooperate with DPAs and provide for "an informal panel of DPAs established at the EU level" to advise companies on compliance (page 26). The FTC commits in Annex IV to coordinate with DPAs on enforcement and to periodic meetings with WP29 on the working of the Privacy Shield (page 65). The sum total of these mechanisms goes beyond arrangements in place for any other third country and any other Article 25(6) Decision. In the Schrems judgment, the Court of Justice of the European Union ("CJEU") gave a clear command to the European Commission to "check periodically"14 whether an adequacy decision is still justified in light of changes in law or circumstances. The Commission will be monitoring "continuously" and will also conduct an annual review that will consider changes in law both in the US and the EU, including the application of the GDPR as of 25 May 2018 and also a dialogue to consider automated processing. The Commission also expresses in clear detail in both its Privacy Shield Communication and the Adequacy Opinion that ongoing review of the Privacy Shield and its operation can lead to suspension if "the level of protection can no longer be regarded as essentially equivalent to the one in the Union" (page 41). In light of these changes, the framework clearly will be subject to rigourous oversight and will not remain static if circumstances warrant change. The annual reviews will provide opportunities to rectify any deficiencies, including any further concerns raised by the WP29 that prove to be problematic in operation. Even if the Commission and the Department of Commerce were somehow inclined to disregard their commitments to careful oversight of the framework, they would be prevented from doing so by the expanded role of DPAs in administration of the Privacy Shield and the scrutiny that the framework undoubtedly will receive in the Parliament, press, and civil society. 4. The Privacy Shield provides a menu of redress options for individuals that ensures a path for judicial review, enables dispute resolution at no cost, and sets deadlines. The provisions for individual redress created in the Supplemental Principles of Annex II offer several paths for individuals to pursue, taking into account a number of considerations from the Schrems judgment and other Safe Harbour criticism through the years. These avenues address the CJEU's criticism of the Safe Harbour Decision that it did not "refer to the existence of effective legal protection against interference"15, and clarify that the US is nowhere near the hypothetical situation of having no 14 CJEU 6 October 2015, Case C-362/14, Maximillian Schrems v. Data Protection Commissioner, ECLI:EU:C:2015:650, para. 76. 15 Schrems, para. 89. 7 datamatters.sidley.com redress options at all ("legislation not providing for any possibility for an individual to pursue legal remedies in order to have access to personal data relating to him, or to obtain the rectification or erasure of such data" would interfere with "the fundamental right to judicial protection").16 First, the Privacy Shield makes available a judicial remedy to obtain rectification or erasure by establishing recourse to an arbitration panel, whose decisions are appealable under the Federal Arbitration Act.17 A second avenue stems from the recommendation of the 2013 Safe Harbour Communication that alternative dispute resolutions be "readily available and affordable." Principle 7 and Supplemental Principles 11 (d) on recourse mechanisms accomplishes this by requiring that subscribing companies make independent recourse mechanisms available "free of charge to individuals". (Annex II, pages 22, 38). Additionally, in Annex I the Commerce Department undertakes to facilitate resolution of disputes referred by DPAs, again with no fees to the individual (page 10). The Notice Principle enhances the functioning of alternative dispute resolution by requiring clearer identification of the redress bodies available (page 19), and the Supplemental Principles define timelines for meaningful resolution (page 38). Finally, in addition to the Commerce Department responding to complaints referred by DPAs, the Recourse, Enforcement and Liability Principle strengthens the role of supervising authorities in dispute resolution by providing for companies to elect to have complaints go to DPAs, and requiring that companies that receive human resources data from the EU do so (page 23). These provisions make it possible for individuals in the EU to go to DPAs and, if DPAs so desire, to receive assistance from these bodies. The ability of DPAs to refer complaints makes it possible for individuals in the EU to bring their complaints to their national supervising authorities rather than US bodies, and for DPAs to act as intermediaries as suggested by WP29.18 These multiple avenues of redress in relation to companies19 ensure that EU data subjects have accessible and affordable recourse that makes it possible to pursue a judicial remedy. The final Decision addresses the concern shared by the WP29, Parliament, and EDPS that these redress choices could be confusing by providing a clear roadmap to the choices and process in "a certain logical order that is advisable to follow". Together with clear and simple notices and 16 Schrems, para. 95. 17 Annex I, pages 12-15. The Federal Arbitration Act, 9 U.S.C. §§ 1 et seq., provides for arbitration of agreements within federal jurisdiction; Section 4 provides for judicial enforcement of agreements to arbitrate and Section 16 allows appeals of an arbitrator's final decision to a federal court. 18 WP238, page 27. 19 For remedies in case of government surveillance, see pages 10 et seq. below. 8 datamatters.sidley.com other publicly accessible explanations, the Commission's roadmap will enable individuals to choose the path most convenient and suitable for them. 5. The strengthened protections of the Privacy Shield establish the effective supervision and detection mechanisms required by the CJEU. In the Schrems judgment, the CJEU held that a system of self-certification like that in the Privacy Shield can be consistent with Article 25(6) of Directive 95/46 provided it establishes "effective detection and supervision mechanisms" to detect and punish fundamental rights to private life and data protection (Schrems, para. 81). The increased scrutiny of certifications and intensified oversight by the Commerce Department; the cooperation among that agency, the FTC, the Commission, and DPAs; and expanded and clearer ways for individuals to protect their rights themselves provide effective detection and supervision mechanisms in the Privacy Shield. In addition to these Privacy-Shield-specific mechanisms, as shown in the Sidley Austin LLP report, Essentially Equivalent: a comparison of the legal orders for privacy and data protection in the European Union and United States (January 2016),20 the general legal order for privacy and protection in the US has changed significantly since 2000, when the Commission approved the Safe Harbour framework. In that time, the US has adopted new sectoral laws and regulations for sensitive data such as health records, financial, and genetic information; data breach notification laws in most states along with other state laws; the FTC role along with that of other agencies has expanded significantly; and privacy officers have become common and influential in US companies. Compared to the earlier framework, the Privacy Shield has much less to supplement in order to ensure that EU citizens retain an equivalent level of protection when data is transferred to the US. Against this backdrop, the increased detail and force in the Privacy Shield framework will ensure that personal data transferred to the US receives protection of fundamental rights and freedoms that is essentially equivalent to that in the EU. 20 See http://datamatters.sidley.com/wp-content/uploads/2016/01/Essentially-Equivalent-Final-01- 25-16-9AM3.pdf 9 datamatters.sidley.com The Major Points of Concern Raised by EU Institutions Are Addressed by the Privacy Shield Framework. The European Commission published its draft Privacy Shield Adequacy Decision on 29 February 2016. Since then, the WP29, EDPS, and Parliament each have weighed in on the draft Decision. In turn, the Commission and the US Government have taken into account concerns raised by these bodies by clarifying and adding to the principles and annexes in the final Decision. The Decision integrates this content into a coherent whole that explains and clarifies how the Privacy Shield addresses the issues raised. In Opinion 238, the WP29 noted that the Privacy Shield reflects "many improvements" over the Safe Harbour framework. The WP29 nevertheless expressed "three major points of concern" (page 57): (A) a perceived absence of rules on deleting data; (B) a perceived failure to exclude absolutely any largescale data collection; and (C) the contribution of the Privacy Shield Ombudsperson to the US redress system. The Parliament and the EDPS each echoed these concerns. The former suggested that the language regarding bulk collection "does not meet the stricter criteria of and proportionality as laid down in the Charter" and the latter suggested a need to get "additional reassurances in terms of necessity and proportionality", and both expressed a need for greater clarity in general. The final Decision and revisions to the annexes from the Commerce Department, State Department, and Office of Director of National Intelligence (ODNI) reflect the lengths the Commission and US Government have gone to address concerns from these bodies. Some of these revisions and clarifications have been touched in the foregoing pages. This section addresses the three recurring major points. 1. The Data Integrity and Purpose Limitation Principle encompasses deletion of data that is no longer relevant or current. The Data Integrity and Purpose Limitation Principle in the Privacy Shield is an expression of the "data quality and proportionality principle" in Article 6(1)(e)21 of Directive 95/46. Although neither that article nor subsequent WP29 adequacy opinions contain explicit language on data deletion, the WP29 expressed concern that the language in the draft adequacy decision did not expressly oblige organisations to delete data that become no longer necessary or obsolete. The final Decision and Principles accommodate this concern by adding to the Data Integrity and Purpose Limitation Principle a requirement that "[i]nformation 21 Pursuant to Article 6(1) of the Data Privacy Directive, "Member States shall provide that personal data must be (…) "(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data were collected or for which they are further processed. Member States shall lay down appropriate safeguards for personal data stored for longer periods for historical, statistical or scientific use". 10 datamatters.sidley.com may be retained in a form identifying or making identifiable the individual only for so long as it serves a purpose of processing [as defined in the prior provision]". This tracks the language of Article 6(1(e) while also incorporating notes and exceptions that anticipate GDPR treatment of "compatible processing", public interest purposes, and re-identification. 2. The findings and reasoning in the draft Adequacy Decision concerning safeguards on US government surveillance are consistent with EU jurisprudence. In its Opinion 238, the WP29 recognised that to date in the EU "there is no conclusive jurisprudence on the legality of massive and indiscriminate data collection and subsequent use of personal data for the purpose of combating crime, including the question under what circumstances such collection and use of personal data could take place" (page 39). WP29 nevertheless expressed a concern that Annex VI of the draft Adequacy Decision (the letter from the US ODNI "does not fully exclude the continued collection of massive and indiscriminate data",22 and stated its view that "such data collection, is an unjustified interference with the fundamental rights of individual". Given the WP29's characterisation of EU jurisprudence, this view appears to reflect mainly a policy statement. Similar views were voiced in the Parliament resolution and EDPS opinion as well. In a long line of cases, the European Court of Human Rights ("ECtHR") has confirmed that Member States have a margin of discretion in setting national rules for collection, storage, and subsequent use of data for national security purposes that is "necessary in a democratic society". In its Opinion WP 237 of 13 April 2016, the WP29 acknowledged that Member States have a "fairly wide margin of appreciation in choosing the means for achieving the legitimate aim of protecting national security" (page 5). This approach, laid down in ECtHR case law since Klass v. Germany23 and again in Weber and Saravia24 shows, for example, that a far-reaching surveillance mechanism must be accompanied by far-reaching safeguards, oversight, and redress. The more intrusive a surveillance mechanism is, and the more "prone to abuse", the higher the safeguards against abuse must be. No particular method of surveillance as such has ever been condemned. The Commission correctly noted in point 89 (footnote 98) of the Decision that the ECtHR has confirmed that "strategic 22 A note on the terminology used by the WP29 and EDPS: the CJEU did not use the term "collection of mass and indiscriminate data" in its legal reasoning in Schrems. The referring Irish High Court used the term "mass and undifferentiated" but only in relation to accessing (Schrems, para. 33). 23 ECtHR [Plenary Court] 6 September 1978, Klass & Others v. Germany, ,ECLI:CE:ECHR:1978:0906JUD000502971. 24 ECtHR 29 June 2006, Weber & Saravia v.Germany (admissibility decision), ECLI:CE:ECHR:2006:0629DEC005493400. 11 datamatters.sidley.com surveillance" covering "a broader range of possible actors" and "a wider geographic area" are permitted under the Weber and Saravia case law. In its Working Document on justification of interferences with fundamental rights of privacy and data protection issued on 13 April 2016 ("WP 237"),25 the WP29 provided a nuanced and thoughtful overview of the criteria for such safeguards in the case law of the CJEU and especially the ECtHR, and correctly distilled from this jurisprudence four "Essential Guarantees" against abuse of surveillance mechanisms. These are (A) clear, precise and accessible rules; (B) demonstration of necessity and proportionality; (C) independent oversight; and (D) effective remedies. The WP29 also acknowledged that proportionality in light of these four Essential Guarantees must not be assessed independently, but on an overall basis. As noted above, there is no rule in EU law that condemns the collection of data as such even if collection occurs on a large scale. In Schrems and Digital Rights Ireland, the CJEU invalidated EU legislative acts because they enabled largescale collection or storage without providing safeguards against abuse and without limiting data access. The CJEU differentiated collection and storage of personal data, which by themselves do not affect the "essence" of data privacy rights, in contrast to access, which does have such effect;26 and discussed objections against unlimited storage and against unlimited access separately. The CJEU indicated it would object to "storage of all the personal data of all the persons whose data has been transferred" where such storage is "without any differentiation, limitation or exception being made, and without an objective criterion … by which to determine the limits of the access" (Schrems, para. 93, emphasis added). The CJEU also would object to "access on a generalised basis to the content of electronic communications" (Schrems, para. 94). As shown in the report by European Union Agency for Fundamental Rights, Surveillance by intelligence services: fundamental rights safeguards and remedies in the EU (2015),27 and the Sidley Austin Essentially Equivalent report referred to above, the laws of a number of EU Member States authorize forms of untargeted surveillance and many Council of Europe countries conduct forms of "bulk, untargeted surveillance by security services". Moreover, on 20 April 2016, the European Commission published its Communication delivering on the European Agenda on Security to fight against terrorism and pave the way towards an effective and genuine Security Union 25 WP29 13 April 2016, Working Document 01/2016 on the justification of interferences with the fundamental rights to privacy and data protection through surveillance measures when transferring personal data (European Essential Guarantees, WP 237, http://ec.europa.eu/justice/data-protection/article-29/documentation/opinionrecommendation/files/2016/wp237_en.pdf. 26 Schrems, para. 93/94; CJEU 8 April 2014, Case C-293/12, Digital Rights Ireland, ECLI:EU:C:2014:238, para. 40. 27 http://fra.europa.eu/en/publication/2015/surveillance-intelligence-services 12 datamatters.sidley.com COM (2016) 230.28 This Communication recalls that the EU Treaties envisage the need to ensure a high level of security, including through preventive measures. The plans include: • "a European common repository of data and EU-integrated biometric identity management for travel, migration and security"; • "an EU Entry Exit System for the EU External border using biometrics, providing for law enforcement access and interoperability with other systems (notably the Visa Information System)"; and • "The existing Prüm framework must be implemented and used fully. It offers automated comparison of DNA profiles, fingerprint data and vehicle registration data". The WP29 suggested that the Tele2 and Davis cases29 pending before the CJEU may change the existing legal order. However, neither case is about "massive and indiscriminate data collection and subsequent use". Rather, these cases involve collection and storage of telecommunications metadata for a limited amount of time, where storage and subsequent use are subject to limitations laid down by national law (as opposed to the general absence of such limits in the Data Retention Directive, the subject of the CJEU judgment in Digital Rights Ireland). In considering the US legal order governing surveillance, WP29 correctly noted that the Foreign Intelligence Surveillance Act ("FISA") does not permit mass and indiscriminate surveillance, and "does not operate by collecting communications in bulk" (WP238, p. 39). The WP29 nevertheless appeared to consider that data transferred to the US are protected only by Presidential Policy Directive 28 ("PPD 28") and Executive Order 12,333. This understanding does not take into account that once such data are within the US, the US government's ability to collect, store, and access these is also constrained by several federal statutes, including FISA and the Electronic Communications Privacy Act ("ECPA"). FISA ‒ including Title I, Section 501, and Section 702 ‒ expressly requires judicial orders authorising collection, and it mandates the use of discriminants when collecting data. The USA FREEDOM Act specifically amended Section 501, which authorises collection of metadata, to prohibit bulk surveillance. Opinion WP238 does not mention ECPA, though it is discussed in Annex VI. This statute governs law enforcement's collection and use of data and requires 28 http://ec.europa.eu/dgs/home-affairs/what-we-do/policies/european-agenda-security/legislativedocuments/docs/20160420/communication_eas_progress_since_april_2015_en.pdf 29 Case C-203/15, Tele2 Sverige AB v. Post- och telestyrelsen; Case C-698/15, Secretary of State for the Home Department v. David Davis, Tom Watson, Peter Brice, Geoffrey Lewis, intervening parties: Open Rights Group, Privacy International, The Law Society of England and Wales, expedited procedure granted by Order of the President of the Court of Justice of 1 February 2016, ECLI:EU:C:2016:70. See WP238, p. 39. 13 datamatters.sidley.com judicial authorisation and the use of discriminants to collect the contents of communications. These protections apply to all data received or stored in the United States, regardless of the sender's or owner's citizenship. The WP29 nonetheless focused on the statement in Annex VI that US law does not entirely exclude bulk collection in certain circumstances, but, as the statutes above make clear, the latter caveat does not affect data transferred to the US under the Privacy Shield. Like any EU Member State, the US can engage in surveillance activities outside of its own territory to protect its national security interests30 (the example in a supplemental letter from the ODNI in Annex VI is "a terrorist group in a region of a Middle Eastern country, that is believed to be plotting attacks against Western European countries") and the Decision notes that foreign intelligence collection as defined in US law is "a legitimate policy objective" (pages 23-24). Such surveillance outside the United States has no bearing on the question whether the transfer of personal data from the EU to the US by Privacy Shield companies would lower the level of protection accorded to such data. Moreover, Annex VI as further clarified by the additional letter from the ODNI makes clear that the circumstances in which such surveillance outside the US can occur are strictly limited ‒ "to identify new and emerging threats and other vital national security interests" within six enumerated purposes ‒ and subject to "the application of methods and tools to filter collection in order to focus collection" on these specific purposes as further refined by policy-makers (pages 79-81, 95-96). Responding to recommendations to clarify this issue, the Commission in turn expanded its review in the final Decision, stressing the limitation under the law to specifically identified purposes, to persons who may have some connection to these purposes, and in circumstances where it is not feasible to target such persons specifically. This meets the standard articulated by the EDPS that untargeted surveillance access "should only take place in exceptional circumstances and where indispensable for specified public interest purposes".31 On this basis, the Commission properly concludes that US intelligence collection in this regard is limited "to what is strictly necessary to achieve the legitimate objective in question". The WP29 and the EDPS raised a concern about the mere possibility of interception of data in transit (through access to transatlantic cables or otherwise). Such collection would have no direct impact on the question whether the act of transferring such data to the US by Privacy Shield companies would lower the level of protection accorded to such data. Moreover, as WP29 recognised, "there continues to be a lack of established jurisprudence determining the legality of cables interception if it were to be carried out by any 30 United Nations Charter, art. 51 (1945). 31 EDPS Opinion, page 2. 14 datamatters.sidley.com country" (WP238, page 36). In other words, there appears to be agreement that cable interception – if it were to occur – would not necessarily infringe EU law or any other laws. For the sake of completeness, it must be noted that the EU could not hold the US to a rule that does not exist in the EU legal order. It would be a plain violation of the GATT and GATS rules if the EU were to prevent data flows to the US on the basis of a "generic risk" that data flowing through cables can be intercepted, whilst permitting data flows between Member States that are subject to precisely the same considerations or data flows to third countries where data transfers may be subject to the same sorts of surveillance that the WP29 raises as concerns.32 Combined with the limitations set out above, these facts show that it is not possible to regard US laws as legislation that "authorizes, on a generalised basis, storage of all the personal data of all the persons whose data has been transferred from the European Union to the United States without any differentiation, limitation or exception being made" (Schrems, para. 93). As shown in the Adequacy Decision, the laws that apply to data that is transferred by companies that subscribe to the Privacy Shield framework contain (A) clear, precise and accessible rules; (B) demonstration of necessity and proportionality; (C) independent oversight; and (D) effective remedies that are consistent with the four Essential Guarantees distilled from EU jurisprudence. Dutch Security and Justice Minister van der Steur concluded in his brief to the Dutch Parliament, "with what the Commission has achieved, in my view the recommendations from the abovementioned 2013 Communication of November 2013, relating to government access to data transferred to the US pursuant to the Shield, have been followed".33 3. The Privacy Shield Ombudsperson will have sufficient authority to perform a complaint review function similar to that of EU supervisory authorities that adds to the avenues of judicial redress available. The WP29 recognised that the commitment to an Ombudsperson to respond to individual EU complaints is an "unprecedented step creating an additional oversight and redress mechanism" relating to government surveillance (WP238, 32 As noted in each of the existing Article 25(6) decisions, these decisions are subject to the EU's international trade law obligations. For at least eight of the eleven such decisions (Argentina, Canada, Switzerland, Faeroe Islands, Israel, Isle of Man, New Zealand and Uruguay), this includes the principles of National Treatment/Most Favoured Nation treatment and the obligation to "administer measures on a reasonable way" (GATS Articles II, XVII, XVI:2(a); GATT 1994, Articles I:1, III:4; X:3(a)). Data privacy protection measures cannot constitute "a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail" (GATT 1994, Article XX(d)). 33 "Kamerbrief over EU US Privacy Shield", page 12 (29 April 2016), https://www.rijksoverheid.nl/documenten/kamerstukken/2016/04/29/tk-brief-eu-us-privacy-shield. 15 datamatters.sidley.com p. 57). In response to desire for clarification of the Ombudsperson's powers on the part of the WP29 and EDPS, the US Department of State has provided additional explanation of the Ombudsperson's independence from and powers over intelligence agencies. As explained in Annex III, the Department of State submission, and reflected in the Commission decision, the official designated as the Ombudsperson is the Under Secretary of State for Economic Growth, Energy & Environment. This Under Secretary is nominated by the President and confirmed by the US Senate, reports directly to the Secretary of State, and is outside the chain of command of those branches of the State Department that deal with national security and intelligence (page 53). The Department of State clarifies that the Secretary will ensure that this official can carry out the Ombudsperson "objectively and free from improper influence", and that that Ombudsperson will be able to refer questions of the lawfulness of surveillance to independent bodies with investigatory powers (which are described in the Annex at pages 57-59). This same Under Secretary is delegated authority under PPD-28, the presidential order that directs US agencies that "[a]ll persons should be treated with dignity and respect, regardless of their nationality or where they might reside, and all persons have legitimate privacy interests in the handling of their personal". PPD- 28 vests the authority "to coordinate with the responsible departments and agencies" and "to serve as a point of contact for foreign governments who wish to raise concerns regarding signals intelligence activities conducted by the United States". The functions of the Privacy Shield Ombudsperson are a specific application of this general authority, and therefore will bring to bear the coordinating authority conferred by the President. The Privacy Shield charges the Ombudsperson to investigate and to establish that US laws and policies have been followed or that any noncompliance has been remedied, without disclosing either whether the complaining individual has been a target of surveillance or what specific remedy may have been applied (page 55). This function is modeled on the role of certain administrative supervisory agencies in the EU. In France and in Italy, for example, the CNIL and the Garante respectively, may review surveillance at the request of individuals, but their review is limited to the regularity under national laws and rules, and they do not confirm or deny surveillance or disclose the disposition of the matter. To be sure, the Ombudsperson will not be a quasi-judicial tribunal, as the WP29 seems to suggest it should be, but the test is not whether the US has adopted avenues of redress that are identical to those in Europe. The test is whether the US provides protection essentially equivalent to the level of protection guaranteed within the EU. The applicable standard guaranteed within the EU does not tolerate "legislation not providing for any possibility for an individual to pursue legal remedies". This does not mean that the EU legal order guarantees universal and automatic 16 datamatters.sidley.com redress in every single situation. Indeed, the case law of the ECtHR specifically notes that data subjects' rights of redress must be balanced in situations of security surveillance – and, as a result, there is no universal or automatic right of redress. As the Plenary Court Judgment in Klass v. Germany noted, "an effective remedy" under Article 13 of the ECHR (the article corresponding to Article 47 of the Charter) "must mean a remedy that is as effective as can be having regard to the restricted scope for recourse inherent in any system of secret surveillance" (para. 69, emphasis added). Moreover, the ECtHR does not provide or require automatic redress, either. There is no actio popularis, 34 and there is no remedy against the "state of domestic law".35 There are no grounds to assume that the US falls short of this standard. In addition to the Ombudsperson introduced by the Privacy Shield, the US has multiple other avenues of redress for unlawful surveillance, which merit more attention than accorded in the WP29 Opinion. The Commission Decision adds several paragraphs setting out these remedies (recitals 130-134). For instance, while it is correct that the Fourth Amendment to the US Constitution alone does not apply to non-US citizens located outside the United States (though PPD-28 extends equivalent protections), there are statutory causes of action that are available to such persons independent of the Fourth Amendment. The WP29 does not address ECPA, which provides criminal sanction as well a civil cause of action for "any person whose wire, oral, or electronic communication is intercepted, disclosed, or intentionally used" in violation of the Act.36 The federal courts have concluded that this cause of action is open to foreign citizens. 37 Similarly, under FISA, "an aggrieved person, other than a foreign power or an agent of a foreign power, . . . who has been subjected to an electronic surveillance or about whom information obtained by electronic surveillance of such person has been disclosed or used in violation of section 1809 of this title shall have a cause of action against any person who committed such violation".38 WP29 dismisses this cause of action as insufficient because it 34 See, by analogy, Klass v. Germany, para. 33: "Article 25 (art. 25) does not institute for individuals a kind of actio popularis for the interpretation of the Convention; it does not permit individuals to complain against a law in abstracto simply because they feel that it contravenes the Convention" (emphasis added). 35 Szabó para. 93: "The Court reiterates that Article 13 cannot be interpreted as requiring a remedy against the state of domestic law (see Ostrovar v. Moldova, no. 35207/03, § 113, 13 September 2005; Iordachi, cited above, § 56). In these circumstances, the Court finds no breach of Article 13 of the Convention taken together with Article 8." 36 18 U.S.C. § 2520(a). 37 See, e.g., Suzlon Energy Ltd. v. Microsoft Corp., 671 F.3d 726, 731 (9th Cir. 2011); see also Privacy and Civil Liberties Oversight Board, Report on the Surveillance Program Operated Pursuant to Section 702 of the Foreign Intelligence Surveillance Act 99 n.444 (July 2, 2014) (citing Suzlon for the proposition that "any person" includes "non-U.S. persons"). 38 50 U.S.C. § 1810. 17 datamatters.sidley.com excludes foreign powers and their agents. But FISA defines a foreign power specifically as a foreign nation, an entity controlled by a foreign government, or an international terrorist organization, and an agent of a foreign power as a person acting on behalf of a foreign government or terrorist organization.39 These definitions do not encompass ordinary citizens of another country. FISA therefore provides another clear available redress mechanism for such citizens. The WP29 also views the doctrine of "standing" as a significant obstacle to obtaining meaningful judicial redress in the United States. It is not accurate to state that such a requirement "nullifie[s]" the availability of review or even that it makes bringing a legitimate suit "very difficult". The federal courts have concluded on multiple occasions that standing exists to challenge bulk and mass surveillance.40 A standing threshold is a common legal standard to multiple comparable legal orders, including to related doctrines governing the jurisdiction of various Member States' courts. It does not bar the doors of court to those with concrete reasons to believe their rights have been violated. In addition to these specific avenues of judicial redress, the US has what the WP29 acknowledges is "a multi-layered approach of both internal and external oversight mechanisms". These include internal agency controls, independent inspectors general within each agency, several congressional committees, the independent Privacy and Civil Liberties Oversight Board, and review by independent judges of a federal court under FISA. The totality of these multiple oversight mechanisms compares favorably to the powers of the UK Investigatory Powers Tribunal approved in the ECtHR Kennedy decision. Against this background, it is valid to conclude that the system of legal redress in the US provides protection that is essentially equivalent to the protection guaranteed in the EU legal order. 39 50 U.S.C. § 1801(a), (b). 40 See, e.g., Am. Civil Liberties Union v. Clapper, 785 F.3d 787, 800-01 (2d Cir. 2015) (holding that plaintiffs have standing to challenge Section 215 metadata program); Klayman v. Obama, --- F. Supp. 3d ---, 2015 WL 6873127, at *8 (D.D.C. Nov. 9, 2015) (same), stay granted, 2015 WL 9010330 (D.C. Cir. Nov. 16, 2015). 18 datamatters.sidley.com CONCLUSION Spurred by the outcome and the principles in the CJEU Schrems judgment and with the input of EU institutions, the Privacy Shield negotiators have produced a robust and detailed framework to protect data that are transferred to the United States. The test is not whether the safeguards in the US subject to this framework are either identical to those in the EU or perfect in all respects. The test is the practical effect of these safeguards, and the framework provides ample opportunity to address ongoing issues through the annual review process. The Commission's conclusion that "the United States ensures an adequate level of protection for personal data transferred under the EU-U.S. Privacy Shield from the Union to self-certified organizations in the United States" is well supported by the evidence discussed in the Privacy Shield Decision and should stand up to legal challenge. Cameron F. Kerry Maarten Meulenbelt Sidley Austin LLP, Boston Sidley Austin LLP, Brussels Sidley Austin LLP represents international clients on data transfers and privacy and data protection matters. Cameron F. Kerry Senior Counsel Boston firstname.lastname@example.com +1 617 223 0305 Cameron F. Kerry is senior counsel in Sidley's Boston and Washington, D.C. offices. He is former General Counsel and Acting Secretary of the United States Department of Commerce, where he played a leadership role in consumer privacy issues and the flow of information and technology across international borders, including on the EU-U.S. Safe Harbour Framework. Cam is also a visiting scholar with the MIT Media Lab and a frequent speaker and writer on privacy and the digital economy. At Sidley, his broad practice operates at the intersection of law, technology and public policy, and is informed by his years of government service and more than three decades in private practice. Maarten Meulenbelt Partner Brussels email@example.com +32 2 504 6467 Maarten Meulenbelt is a partner in Sidley's Brussels office. He has extensive litigation experience before the EU Courts, national courts and competition authorities, the European Commission and national regulatory authorities in several EU Member States with a specific focus on the life sciences sector. He is a member of Sidley's Privacy, Data Protection and Information Law, Global Life Sciences and Antitrust practices focusing on EU regulatory affairs, litigation and competition law issues affecting clients in Europe. ABOUT THE AUTHORS Sidley Austin LLP is a premier global law firm celebrating its 150th anniversary in 2016. With more than 1,900 lawyers and 20 offices worldwide, the firm provides a broad range of services to meet the needs of large and small businesses and other organizations across a multitude of industries, forums and governments. Sidley has a broad transactional practice and consistently ranks among the top global capital markets firms. Sidley also has an extensive litigation and arbitration practice, spanning nearly every area of substantive law. The firm also provides regulatory counseling and advocacy regarding communications, energy, environmental, food, drug and device, healthcare, insurance, Internet, life sciences, financial and securities law, and represents clients in virtually every major industry. Sidley is rated among the top law firms, recognized in the United States and globally for service and responsiveness, and widely recognized for its pro bono and diversity programs. Sidley's Privacy, Data Security and Information Law practice group is a global and interdisciplinary team of lawyers focused on a broad range of emerging issues, including privacy and data protection; cybersecurity and data breach preparedness and response; Big Data; government surveillance; data localization; Internet law; cross-border data flows; and e-Commerce. The group handles litigation and investigations, cybersecurity compliance and regulatory counseling, data breach incident response, legislative and policy developments and sector-specific counseling internationally. Clients cover a broad range of industries. The practice and its lawyers consistently rank in the top tiers of Chambers USA, Chambers Global, and The Legal 500. AMERICA • ASIA PACIFIC • EUROPE sidley.com Attorney Advertising - For purposes of compliance with New York State Bar rules, our headquarters are Sidley Austin LLP, 787 Seventh Avenue, New York, NY 10019, 212 839 5300; One South Dearborn, Chicago, IL 60603, 312 853 7000; and 1501 K Street, N.W., Washington, D.C. 20005, 202 736 8000. Sidley and Sidley Austin refer to Sidley Austin LLP and affiliated partnerships as explained at www.sidley.com/disclaimer. Prior results do not guarantee a similar outcome. MN-4314-07/16


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MANILA, Philippines A hole the size of a small car in the underside of a Qantas jumbo jet carrying 346 passengers forced the pilot to make an emergency landing Friday after a rapid descent over the South China Sea.
The Boeing 747-400 was cruising at 29,000 feet when a loud bang rattled the plane. Video shot by a passenger shows people sitting with their oxygen masks on as the jet descended quickly to 10,000 feet. Applause erupted as the plane touched down safely.
There were no injuries, but some passengers vomited after disembarking, said Octavio Lina, Manila International Airport Authority deputy manager for operations.
An official at the U.S. Transportation Security Administration, who spoke on condition of anonymity because the incident was not domestic, said initial reports show it was not related to terrorism.
"From the pictures coming in from Manila it's quite evident that a section of the fuselage gave way in flight," Jane's Aviation Expert Chris Yates said in a statement. "As a consequence of this the aircraft experienced rapid decompression. Fast action from the pilot and co-pilot ensured that all those aboard remained safe."
Investigators will now determine whether metal fatigue or manufacturing defect caused the panel to be ripped away from the remainder of the fuselage in flight, Yates said.
The aircraft appeared to be missing a plate of its metal skin at the joint where the front of the right wing attaches to the plane. A curved line of rivets was still visible on the body at the front edge where the sheet once was; a straight line of rivets is along the other.
Flight QF 30, from London to Melbourne, had just made a stopover in Hong Kong.
"One hour into the flight there was a big bang, then the plane started going down," passenger Marina Scaffidi, 39, from Melbourne, told The Associated Press by phone from Manila airport. "There was wind swirling around the plane and some condensation."
She said the hole extended from the cargo hold into the passenger cabin.
"No one was very hysterical," she said.
June Kane of Melbourne described how parts of the plane's interior broke apart in the depressurized cabin.
"There was a terrific boom and bits of wood and debris just flew forward into first (class) and the oxygen masks dropped down," she told Australia's ABC Radio. "It was absolutely terrifying, but I have to say everyone was very calm."
A report by the Manila International Airport Authority, quoting pilot John Francis Bartels, said the plane suffered an "explosive decompression." Australia's air-safety investigator said an initial investigation suggested "a section of the fuselage separated."
Lina said the cabin's floor gave way, exposing some of the cargo beneath and part of the ceiling collapsed.
"There is a big hole on the right side near the wing," he said, adding it was 7 1/2 feet to 9 feet in diameter.
Bob Vandel, executive vice president of the independent, Virginia-based Flight Safety Foundation, said the hole caused the plane to lose pressure and oxygen, which required the pilot to start a quick, initial descent to normalize oxygen levels, said Vandel.
"The plane lost pressure, so the pilot had to get the aircraft down below 12,000 feet pretty quickly," said Vandel.
The video shot by a passenger showed people sitting with their oxygen masks on just-served meals on their tray tables. Cabin crew continued to work, walking down the aisles and showing no sign of panic.
Geoff Dixon, the chief executive officer of Qantas, praised the pilots and the rest of the 19-person crew for how they handled the incident.
"This was a highly unusual situation and our crew responded with the professionalism that Qantas is known for," he said.
Qantas Australia's largest domestic and international airline boasts a strong safety record and has never lost a jet to an accident, although there were crashes of smaller planes, the last in 1951. Since then, there have been no accident-related deaths on any Qantas jets.
However, the airline has had a few scares in recent years. In February 2008, a Qantas 717 with 84 passengers on board sustained substantial damage in a heavy landing in Darwin, Australia.
In addition, union engineers who have held several strikes this year to demand pay raises say that safety is being compromised by low wages and overtime work.
Qantas touts itself as the world's second-oldest airline, founded in 1920. As of December 2007, Qantas was operating 216 aircraft flying to 140 destinations in 37 countries, though in recent months it has announced it will retire some aircraft and cancel some routes as well as cutting 1,500 jobs worldwide due to skyrocketing fuel prices.
Late Friday, the passengers boarded another plane for Melbourne. The damaged plane was towed to a hangar in Manila.
Chief Superintendent Atilano Morada, head of the police Aviation Security Group, said his officers, including explosives experts, may assist in the airline's investigation.
"So far, they don't want us to touch it, so we will respect the aircraft owner. But we will make our personnel available if they need assistance in the investigation," he said.
The incident carried some echoes of a 1988 incident in which a large section of an older Aloha Airlines jetliner was torn off over Hawaii because of metal fatigue. Although the pilots were able to land, a flight attendant died and many of the 89 passengers were seriously injured.


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Thu, 16 Nov 2017 by jagadeeswaran in Building and Construction I have booked for 2 bhk flat in TGS Mouritious in Kengeri on Mar 26 2016 by paying an amount of Rs.4 63 000 Till now no update about the project. Please file a complaint n look into the matter... Read more
Mon, 20 Mar 2017 by in Real Estate I have booked for 3 bhk flat in TGS Maldives in new bel road on Mar 26 2016 by paying an advance amount of Rs.17 05 000 Till now no update about the project. Please file a complaint n look... Read more
Thu, 02 Mar 2017 by VijayaPrakash in Building and Construction I the undersigned working as a public servant in HMT Machine Tools limited kindly bring to your notice as below I in the year 2015 December month received a call from TGS Constructions representative for an offer to Maldives Project.Thereby... Read more
Sun, 22 Jan 2017 by Divyashree in Real Estate Hi Bangalore Police I have booked plot in my mother s name on 2015 September for project TGS Saraswathi kanakpura Road and the possession date given by them was October 2016. From past 6 months I did not received any... Read more
Thu, 29 Dec 2016 by in Real Estate Sir I booked plot in tgs construction pvt ltd under dhanalashmi project which is located in mysore road. I paid advance of rupees 536000 against the property through cheques . Now I came to know that company is not liable... Read more


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An Excerpt From My 2002 Journal (with footnotes from 2017)
So when I was reading Amy Schumer's The Girl With The Lower Back Tattoo this was a tool she would frequently use throughout her book and I thought it would be fun to try on my own. My parents are retired and working on purging their house so I've had to claim a lot of my childhood crap including my journals. Yes I was a young closeted gay boy who wrote in a journal because it was the early 00s and I had a lot of feels.
January 17th, 2002
Okay this the worst week. Omg first I have 2 projects due and one done and I'm starting one next week plus exams this week.[1] Plus exams this week during my math exam I got low and it sux. [2] It's Lindsey's birthday and I didn't get her anything because she has been treating me like dirt lately. [3] I start gym and computer next week and the only good thing is no more Mr. Raymer and no more wood tech and asshole 8th graders. [4]
There is a new episode of Charmed and new Friends tonight.[5] They find of out the sex of Rachel's baby is tonight and I hope it's a girl. [6]
The Next Day….
It's a girl on Friends [7] Right now I've decided to this summer I want a Homer Simpson attitude I want to be lazy but not dull and be exciting but also effortless. [8] I had my gym orientation and it doesn't seem that bad but computer does suck and I don't want to go[9]
-Rob Dine
[1] I mean it's not exactly an episode of Degrassi level panic.
[2] I'm assuming I mean a low blood sugar and that is how I spelled "sucks" in the journal. #AOL
[3] Oh man now we are spilling the tea Also I still remember Lindsey's Birthday is January 18th. Sorry girl no ill will in 2017.
[4] I remember having a lot of anxiety about gym, and with wood tech the semester before it wasn't the easiest place to be closeted. I also remember I was in Mr. Raymor's class when 9/11 happened.
[5] Must be Thursday
[6] I won't spoil anything for people living under a rock.
[7] Spoiler alert
[8] Real talk: this is still my aspiration and I completely forgot its origin. Also even in 2002 the main thing I seem to care about is television.
[9] It turns out Mr. McNally was a huge prick but I wouldn't be typing this blog if he hadn't scared me into learning home row.
For you die-hard fans out there, here is a picture of me on NYE going into 2002 and where I made the resolution to start jounaling. I hope that blows your mind. Also don't worry it's just kids champagne and those are just terrible frosted tips.


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I've spent most of last and this month on things other then painting and assembling models for once.
Played some apocalypse, played some computer games, and played a game against Necrons with my Eldar.
The Necron game really made me want to start working on my own necrons, and as such that is what I'm currently up to.
I only just started these, so they're very much work in progress, but that'll change quite soon.
Currently I'm working on a squad of warriors, a destroyer, overlord and some scarabs.
|The mighty?? Necron warhost
The destroyer currently still has the standard green rods, but I want these necrons to stand out a bit more, so those, and the rods for the warriors, will be replaced with blue rods as soon as I get them in.
This is also the reason for the blue orbs and such on the overlord.
|Overlord with ressurection orb
|Overlord side view
|Overlord rear/side view
The catacomb command/annihilation barge that came with the overlord, I still need to magnetize some bits on, so that will be in a future update, as well as hopefully some more paint work on these models.


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Use of SNP genotyping to determine pedigree and breed composition of dairy cattle in Kenya
TypeJournal Article
AccessibilityLimited Access
MetadataShow full item record
Gorbach, D.M., Makgahlela, M.L., Reecy, J.M., Kemp, S.J., Baltenweck, I., Ouma, R., Okeyo, A.M., Marshall, K., Murdoch, B., Moore, S. and Rothschild, M.F. 2010. Use of SNP genotyping to determine pedigree and breed composition of dairy cattle in Kenya. Journal of Animal Breeding and Genetics 127(5):348-351.
Permanent link to cite or share this item: https://hdl.handle.net/10568/3496
High levels of inbreeding in East African dairy cattle are a potential concern because of use of a limited range of imported germplasm coupled with strong selection, especially by disease, and sparse performance recording. To address this, genetic relationships and breed composition in an admixed population of Kenyan dairy cattle were estimated by means of a 50K SNP scan. Genomic DNA from 3 worldwide Holstein and 20 Kenyan bulls, 71 putative cow-calf pairs, 25 cows from a large ranch and 5 other Kenyan animals were genotyped for 37 238 informative SNPs. Sires were predicted and 89% of putative dam-calf relationships were supported by genotype data. Animals were clustered with the HapMap population using Structure software to assess breed composition. Cows from a large ranch primarily clustered with Holsteins, while animals from smaller farms were generally crosses between Holstein and Guernsey. Coefficients of relatedness were estimated and showed evidence of heavy use of one AI bull. We conclude that little native germplasm exists within the genotyped populations and mostly European ancestry remains.
SubjectsANIMAL BREEDING; DAIRYING; GENETICS; LIVESTOCK;
RegionsAFRICA; EAST AFRICA
- ILRI articles in journals [5051]