‘no deal’ Brexit – Personal Data Transfers

4th January 2019

For those that might have missed it… The Data Protection Commissioner has issued guidance regarding Personal Data Transfers to and from the UK https://dataprotection.ie/en/news-media/latest-news/dpc-issues-important-message-personal-data-transfers-and-uk-event-no-deal , including Northern Ireland, in the event of a ‘no deal’ Brexit. The main points of her guidance are:

In the event of a “No Deal” Brexit, (and that European Commission does not make an adequacy decision regarding the UK at the point of exit) and where your organisation has Personal Data Flows from the EU to the UK, you should now consider:

  • Mapping the personal data being transferred to the UK (including Northern Ireland) currently. Consider outsourced Payroll service providers, IT/data servers located in the UK, security monitoring ARCs based in the UK, Insurance and HR service providers
  • Assess the various transfer mechanisms to decide which ones best suit the situation
  • Be ready to implement a suitable transfer mechanism in the event of a “No Deal” Brexit.

If you would like any additional information or advice as to how to prepare for this particular challenge, contact our Data Protection team on 042 9743040