The agreement reached between the EU and the UK on Brexit also addresses the regime for transfers of personal data, with some unexpected developments. It is not a surprise that the EU-UK trade cooperation agreement has a section dedicated to data protection matters. In particular, the privacy-related terms of the Brexit deal provides in relation to data transfers that there will be a maximum 6-month transitional period in which transfers of personal data from the EU towards the UK will be free with the UK that will not be considered to a “third country” and therefore no standard contractual clauses or other means provided by articles 46 or 49 of the GDPR will be necessary, and likewise During such a period, the UK recognized EEA privacy laws to be adequate for data transfers from the UK to the EEA; but The transitional period might be shorter if the European Commission early adopts a decision of adequacy; and To ensure that the UK does not become the door to uncontrolled transfers towards third countries, during the transitional period, the UK will not issue Art 45 adequacy decisions or Art 46 approved safeguards for transfers without prior EU approval. https://www.gamingtechlaw.com/2020/12/privacy-brexit-deal-impact-transfers-data.html
