- On 14 December 2018
This week has brought further uncertainty on the route to Brexit. The planned vote in the UK Parliament on the Withdrawal Agreement – intended to establish an orderly transition period for the UK to withdraw from the EU between 30 March 2019 and 31 December 2020 – has been postponed leaving considerable uncertainty as to next steps, including the prospect of a ‘hard’ departure on 30 March 2019 with ‘no deal’ in place. As we write, the UK Prime Minister is attempting to obtain further concessions from the EU, but all the time the clock is ticking and barring other eventualities – such as the cancellation of Brexit (on the basis of a second referendum or otherwise), it is a no-deal Brexit which remains the default position if no alternative option can achieve consensus.
Whether the UK leaves the EU with a ‘deal’ or ‘no deal’ scenario there will be a material impact on the way in which organisations manage the flow of personal data between the EU and the UK in the future, with a ‘no deal’ scenario significantly accelerating many of the challenges.
Given the escalating risk of the UK leaving the EU on a ‘no deal’ basis, it is critical for organisations to plan ahead now to understand the likely implications and be ready to act, potentially as soon as 29 March 2019.
We have produced a GDPR Brexit flowchart which maps out the key data protection impacts for each of the political routes that may now follow, showing the likely timelines and implications of both the ‘deal’ and ‘no-deal’ scenarios, which we hope will be a useful tool in contingency planning through these uncertain and difficult times.