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Data Transfers Under the GDPR in Case of a No-Deal Brexit

Data Transfers Under the GDPR in Case of a No-Deal Brexit

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In the absence of an agreement between the EEA and the UK (no-deal Brexit), the UK becomes a „third country” as of 00.00 am CET on 30 March 2019. This means that the organisations should revise those of their processing activities, which imply transfer of personal data to the UK.

The European Data Protection Board (EDPB) adopted an information note on 12 February 2019, which provides further details to commercial and public organisations for the transfer of personal data to the UK in the event of a no-deal Brexit. The EDPB recommends the following 5 steps organisations should take to prepare for a no-deal Brexit, when transferring data to the UK:

  1. Identify what processing activities will imply a personal data transfer to the UK; 
  2. Determine the appropriate data transfer instrument (see Chapter V of GDPR) for the organisation’s situation;
  3. Implement the chosen data transfer instrument to be ready for 30 March 2019;
  4. Indicate in the internal documentation that transfers will be made to the UK; 
  5. Update the privacy notice accordingly to inform individuals. 

As to the data transfers from the UK to EEA Member States, according to the UK Government, the current practice (i.e. which permits personal data to flow freely from the UK to the EEA) will continue in the event of a no-deal Brexit

By Adrienn Megyesi, Attorney at law, KCG Partners Law Firm

Hungary Knowledge Partner

Nagy és Trócsányi was founded in 1991, turned into limited professional partnership (in Hungarian: ügyvédi iroda) in 1992, with the aim of offering sophisticated legal services. The firm continues to seek excellence in a comprehensive and modern practice, which spans international commercial and business law. 

The firm’s lawyers provide clients with advice and representation in an active, thoughtful and ethical manner, with a real understanding of clients‘ business needs and the markets in which they operate.

The firm is one of the largest home-grown independent law firms in Hungary. Currently Nagy és Trócsányi has 26 lawyers out of which there are 8 active partners. All partners are equity partners.

Nagy és Trócsányi is a legal entity and registered with the Budapest Bar Association. All lawyers of the Budapest office are either members of, or registered as clerks with, the Budapest Bar Association. Several of the firm’s lawyers are admitted attorneys or registered as legal consultants in New York.

The firm advises a broad range of clients, including numerous multinational corporations. 

Our activity focuses on the following practice areas: M&A, company law, litigation and dispute resolution, real estate law, banking and finance, project financing, insolvency and restructuring, venture capital investment, taxation, competition, utilities, energy, media and telecommunication.

Nagy és Trócsányi is the exclusive member firm in Hungary for Lex Mundi – the world’s leading network of independent law firms with in-depth experience in 100+countries worldwide.

The firm advises a broad range of clients, including numerous multinational corporations. Among our key clients are: OTP Bank, Sberbank, Erste Bank, Scania, KS ORKA, Mannvit, DAF Trucks, Booking.com, Museum of Fine Arts of Budapest, Hungarian Post Pte Ltd, Hiventures, Strabag, CPI Hungary, Givaudan, Marks & Spencer, CBA.

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