Readiness for Brexit – Data Protection and GDPR
As you’ll be aware, the UK leaves the EU on 31st January 2020 and then enters into an implementation period to 31st December 2020 in which transitional arrangements apply whilst negotiations take place regarding final arrangements on data protection amongst other matters. Like all UK organisations, The Myers-Briggs Company Limited faces some uncertainties in terms of the outcome of the UK-EU trade and other negotiations.
Therefore, for the purposes of our business planning, we continue to prepare for the possibility of a no-deal Brexit scenario (where we have exited the EU on 31st January 2020 but have not agreed all trade and other arrangements before the end of the transition period on 31st December 2020 and no transition period extension is agreed). This would mean there would be no adequacy decision given in respect of the UK and GDPR, and the UK would, in terms of data protection, be deemed a “third country”
Whilst, in such event, we will continue to operate in terms of data protection in fundamentally the same manner as we do now, we are currently making the necessary preparations to action on 31st December 2020, certain additional measures and processes which will implement the changes and protections needed in view of the UK then being deemed a third country. Such measures and processes will ensure we remain compliant with UK and EU data protection laws, namely continuing compliance with both GDPR standards and the UK national data protection legislation (including the Data Protection Act 2018 and any additional or enacting legislation, together with ICO guidance)
Such measures and processes would include:
- model contracts to be entered into between our UK and EU offices;
- amendments to our standard terms of business to alter references to applicable legislation and the UK being a third country within the Data Processing Terms schedule of our Terms of Business;
- amendments to our European offices’ standard terms of business; and
These changes will be implemented on 31st December 2020 if there is no adequacy decision given in respect of the UK’s data protection arrangements by that date.
In the meantime, you can view:
- our current Data Protection Statement, in relation to our stance on data protection generally
- our Brexit statement, in respect of our stance on Brexit and preparations generally.
We will be in touch with all our customers via Marketing messages, alerts on OPPassessment and messages on our website, so please do monitor these as the end of the transition period approaches. We will be communicating further via these channels once the outcome is clearer.
If you have any questions regarding data protection in the event of Brexit or otherwise, please do contact us on firstname.lastname@example.org.
The Myers-Briggs Company Limited
15-17 Elsfield Way
Oxford OX2 8EP
T: + 44 1865 404500