On January 31, 2020, the International Trade Association’s Privacy Shield Team issued guidance concerning changes to Privacy Shield Framework in the wake of the United Kingdom’s exit from the European Union. For those wondering how Brexit will impact cross-border data transfers, here are a couple items to note.
First, during the Transition Period from January 31, 2020 until December 31, 2020, EU laws governing the Privacy Shield Framework remain in place and no additional action is required on the part of Privacy Shield participants.
Second, once the Transition Period ends, Privacy Shield participants will be required to:
1) Update their public commitment to comply with Privacy Shield to expressly include the UK. The model language for adding a UK commitment is as follows:
2) Organizations must also maintain their current Privacy Shield certification, and recertify annually as required by the Framework.
For additional information, please see the following: https://www.privacyshield.gov/article?id=Privacy-Shield-and-the-UK-FAQs