Readiness for Brexit – Data Protection and GDPR
Like all UK organisations, The Myers-Briggs Company Limited is facing some uncertainties in terms of the UK exiting the EU and the outcome of the UK-EU Brexit negotiations.
Whilst we hope that matters will be clarified shortly, for the purposes of our business planning, we continue to prepare for the possibility of a no-deal Brexit scenario (where no Brexit deal is agreed between the UK and EU parliaments by 31st October 2019 and we still exit the EU on that date). This would mean there would be no transition period and since there is currently no adequacy decision in respect of the UK and GDPR, the UK would, in terms of data protection, be deemed a “third country”.
Whilst, in the event of a no-deal Brexit, 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 that day, 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 GDPR standards and also compliance with the UK national data protection legislation that will apply on a no-deal Brexit (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 October 2019 if there is a no-deal Brexit on that date, or such later date of any no-deal Brexit.
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 deadline 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.
Betsy Kendall, DPO
The Myers-Briggs Company Limited
15-17 Elsfield Way
Oxford OX2 8EP
T: + 44 1865 404500