International Data Transfer - a UK perspective on 2021 and 2022

Following the landmark Schrems II case in 2020, there has been significant global focus on the regulation of international data transfers. There has been a particular focus on how the UK fits into the picture following its departure from the EU, and there have been some important developments during 2021 and so far in 2022 which either directly impact the UK or have a bearing on its direction of travel. Our timeline below tracks a selection of these key developments. With the ICO’s template "International Data Transfer Agreement" and "SCC Addendum" coming into force on 21 March 2022, and DCMS setting the tone for ambitious reforms to the UK’s data protection regime including in connection with “reducing barriers to data flows”, 2022 promises to be equally as significant as 2021, and a year for organisations in or with a nexus to the UK to focus on their international data transfer arrangements.

Timeline

1 January 2021

The UK becomes a "third country" for the purposes of the GDPR

Read here

4 June 2021

Commission issues modernised standard contractual clauses

Read here

28 June 2021

UK deemed adequate for transfers of personal data from the EU

Read here

11 August 2021

The Information Commissioner's Office (the "ICO") launches public consultation on how organisations can continue to protect personal data when it is transferred outside of the UK

Read here

10 September 2021

DCMS issues consultation on reforms to the UK's data protection regime

Read here

21 March 2022

The UK IDTA and SCC Addendum come into force on 21 March 2022, subject to Parliamentary approval

Read here

If you would like any advice or assistance with your international data transfer arrangements, please contact George Willis (george.willis@northridgelaw.com) or Nick Dutton (nick.dutton@northridgelaw.com).

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