Do any of these things pertain to your business?
- Are you outsourcing your HR, IT or payroll function to a UK-based organization?
- Are you using a UK-based marketing company to send marketing communications to your customer database?
- Is your occupational health provider based in the UK?
- Is your pension scheme based in the UK?
- Are you using translation/transcribing services of a UK-based company where you might be sending personal data of employees, customers or suppliers?
- Are you using a UK-based company to analyze data on visitors to your website?
- Are you storing data in the UK on a server or in the cloud?
If yes to any, and you are an EU entity, then you are transferring data to the UK and need to make arrangements with the UK leaving the EU on December 31, says the Ireland Data Protection Commission in a guidance on post Brexit data transfers.
In the absence of an adequacy decision you will need to incorporate standard contractual clauses into your agreement with UK entities and will need to conduct a Schrems II transfer impact assessment to determine what supplemental measures may be needed in addition to the clauses.
Read the full text of the guidance.