The UK Government has produced a series of technical notices
explaining what businesses might need to do if there is a "no
deal" Brexit. While it considers this "unlikely given the
mutual interests of the UK and the EU in securing a negotiated
outcome", the Government says it needs to prepare for all
eventualities and suggests organisations should do the same. One of
these notices concerns the crucial area of data protection and the
possibility that, in a no deal scenario, the UK will not have
secured an adequacy decision from the European Commission allowing
the unrestricted transfer of personal data from the EU to the
UK.
The UK Government's notice, Data protection if there's no Brexit deal
published on 13 September, explains that if the UK leaves the EU in
March 2019 with no agreement in place regarding future arrangements
for data protection, there would be no immediate change in the
UK's own data protection standards. This is because the Data
Protection Act 2018