All Privacy Shield participants should be prepared — possibly as soon as March 30, 2019 — to update their Privacy Shield commitments in order to receive personal data from the UK in reliance on the EU-U.S. Privacy Shield Framework
The timing of this required update depends on whether the UK Parliament approves the agreement on the terms of the UK’s exit from the EU on March 29, 2019 (“the Withdrawal Agreement”). The Withdrawal Agreement provides for an 18-month transition period in which EU law, including the data protection law and the Privacy Shield adequacy decision, will continue to apply to and in the UK. During the transition period, the United States will consider a Privacy Shield participant’s commitments to comply with the Privacy Shield Framework to include personal data received from the UK in reliance on Privacy Shield. Provided the UK Parliament approves the Withdrawal Agreement, Privacy Shield participants will not need to update their Privacy Shield commitments until December 31, 2020.
Read our client alert.