Now that the UK has left the EU, there is a transition period which is expected to end at the 31st December 2020, to allow time to negotiate a new relationship with the EU. During the transition period the GDPR will continue to apply in the UK.
But what will the end of the transformation period mean for organizations offering goods or services to individuals in the EU and the UK or monitoring the behavior of individuals in the EU and the UK ?
The below chart takes into account the requirements to appoint a representative in the UK in the event of a no-deal Brexit. If the UK remains in the EU or leaves with a deal, different answers will apply.
But what will the end of the transformation period mean for organizations offering goods or services to individuals in the EU and the UK or monitoring the behavior of individuals in the EU and the UK ?
- Organizations established outside the EU and the UK: currently, these organizations require one representative based in the EU and one based in the UK.
- Organizations established in the UK: organizations established in the UK but which offer goods or services to, or monitor, individuals in the EU will need to appoint a representative in an EU country;
NB International organizations providing goods or services to the EU, whose only EU office is located in the UK will have the obligation to appoint a "new" EU Data Protection Representative and - Organizations established in other EU countries: organizations established in the EU but not in the UK, which offer goods or services to, or monitor, individuals in the UK will need to appoint a representative in the UK following Brexit. This will be needed to comply with UK law.
The below chart takes into account the requirements to appoint a representative in the UK in the event of a no-deal Brexit. If the UK remains in the EU or leaves with a deal, different answers will apply.
