In order to identify whether and how Brexit will impact processing activities in your company, there are several questions that should be asked.


In case of a no-deal Brexit, the UK will become a third country within the meaning of the GDPR. This would mean that, as of the withdrawal date, any transfer of personal data to the UK would have to be based on one of the transfer mechanisms listed in Chapter V of the GDPR.


Even if the UK does not provide an adequate level of protection of personal data as required by the GDPR, a transfer of personal data to the UK will still be possible if you choose and implement one of the available personal data transfer mechanisms.


The changes that you may have to make following Brexit will need to be reflected in your privacy policy/information notice towards data subjects, and in your internal policies and your GDPR-related documents.


Brexit may have an impact on which supervisory data protection authority is competent for one or more of your data processing activities. After Brexit this will depend on whether you perform cross-border processing, and where you are established.


In an earlier blog post, Timelex presented the CITADEL project, a project that built several ICT to tools to help governments (public administrations) to understand why citizens do or do not use a certain service, how existing services can be optimized and what is needed to create new and better public services.

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Privacy & data protection

Do you use one of the Facebook plugins, such as the ‘Like’ button, to anticipate your website visits? Then you might be a joint controller with Facebook. This follows from a recent judgment of the European Court of Justice (‘CJEU’) in the Fashion ID judgment (C-40/17).

Privacy & data protection

The Danish supervisory authority proposes to impose a fine of DKK 1.5 million (approximately € 200,000) on a Danish furniture manufacturer (IDDesign) for failing to comply with the obligations regarding the retention periods of personal data.

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