Normal service will be resumed with the full range of insight newsletters next week, but I wanted to give you a quick update on where we are:
- The UK signed the EU-UK Trade and Cooperation Agreement on 30th December, and this came into effect on 1st January 2021.
- One piece of this (clause 4 on page 607) refers to data protection (you can read it here) and confirms that personal data can flow from the EEA into the UK for 4 months (maybe extended to 6 months) whilst we await the EU decision on adequacy. This means the pressure is off just now.
- Provided you could demonstrate compliance (with respect to UK-EEA data transfers) at 31st December, you should still be able to in January 2021.
- The ICO website confirms this, and will be updated regularly.
You should have changed your privacy notice to reflect UK GDPR, which is now separate from EU GDPR, and I recommend that you undertake a GDPR review if you haven’t done one for a while (I can guide you through this so just get in touch if I can help)