IF Brexit AND Privacy Shield THEN (amend privacy notice).

If you use the EU U.S. Privacy Shield mechanism to transfer Personal Data from the UK to the U.S., you will need to amend your privacy disclosure to state specifically that the commitment extends to personal data received from the UK in reliance on Privacy Shield – say new FAQs on the Privacy Shield website.

In case of a “no-deal Brexit,” you will need to make the amendments by March 29, 2019.

In case of a “soft Brexit,” you will need to make the amendments by December 31, 2020 (the end of the “transition period”).

Sample language provided on the site is: “(INSERT your organization name) complies with the (INSERT EU-U.S. Privacy Shield Framework [and the Swiss-U.S. Privacy Shield Framework(s)]) (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the (INSERT European Union and the United Kingdom and/or Switzerland, as applicable) to the United States in reliance on Privacy Shield… ”

Details from Privacy Shield.

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