The impact of the Brexit deal on personal data transfers from the EU to the UK
- Articles and memoranda
- Posted 31.03.2021
On 24 December 2020, the European Union ("EU") and the United Kingdom ("UK") finally struck a deal over Brexit. They notably reached a Trade and Cooperation Agreement.
In respect of personal data protection, this Trade and Cooperation Agreement provides for a temporary period during which transfers made to the UK will not be considered as transfers within the meaning of the laws of the EU law, insofar as – inter alia – the UK Data Protection Act 2018 ("DPA") as amended in 2019 applies. The DPA was amended to incorporate the principles of the GDPR and has become the so-called UK GDPR. It will be applicable from 1 January 2021.
Should the UK not be granted an adequacy decision by the end of the temporary period (ending at the end of April or, if extended, June 2021), the situation will then be as if no deal intervened in this respect.
Please read our article here.
The European Commission recently released two draft decisions on the adequate protection of personal data by the United Kingdom.
Please read our article here.