Privacy Shield and Brexit

It is almost time for the UK to crash out of the EU, or gracefully exit the EU.

In anticipation of both scenarios, the U.S. Department of Commerce issued updated guidance to Privacy Shield participants on international transfers of personal information (see link).

In summary:

If the UK gracefully exits, there will be a transition period up to December 31, 2020 where no changes are needed.

If the UK crashes out (or after the transition period), a Privacy Shield participant must revise their public commitment to include the UK (see link).

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