To butcher a catchphrase from a certain wildly popular HBO show: Brexit is coming. Whatever form of Brexit takes place, and whenever it may be, one thing is clear: UK organisations need to prepare themselves.
John O'Brien explores key themes emerging from the ICO and UK government on how best to prepare for Brexit.
Previous articles (see for example ‘Brexit: key impacts on data protection’ by James Clark & Alexandra Greaves, Volume 19 Issue 1, pages 6-8) and commentary in this journal have covered the types of issues that UK organisations will need to consider. Towards the end of 2018, the UK government and regulator began to issue concrete guidance:
- the Information Commissioner’s Office (‘ICO’) issued guidance on the impact of Brexit on UK companies that process personal data; and
- the Department for Digital, Culture, Media & Sport (‘DCMS’) issued guidance on UK data protection law amendments in the event of a ‘no deal’ Brexit.
The government has also laid secondary legislation before the Houses of Parliament to amend domestic legislation governing personal data processing, electronic direct marketing and cookies. Some common themes emerge from the guidance and legislation. This article is a whistle-stop tour of the guidance that UK businesses have received. It is intended to help concentrate minds about what organisations can do now to prepare for Brexit.
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