4 ms·
This is a bit late. For most people this is a footnote, but for you it actually matters. The UK passed (implemented?) GDPR as a law while it was in the EU, and
by lmkg 6y ago
This is a bit late. For most people this is a footnote, but for you it actually matters.
The UK passed (implemented?) GDPR as a law while it was in the EU, and will retain that law after it leaves the EU. However, its interpretation of GDPR will be allowed to diverge. For one thing, the court case "Schrems II" is from an EU case post-Brexit, so it is not binding on the UK's interpretation of GDPR. This is going to be a pain point for the UK as it attempts to maintain data flows with the EU.
I overstated and got confused about Switzerland's relationship to GDPR. I for some reason thought they signed a treaty with the EU had materially similar terms as GDPR. It seems what's actually in effect is an Adequacy Decision, where the EU recognizes Switzerland's data protection laws as being "good enough" that all data transfers to Switzerland don't need extra protections.
Part of my confusion is that Switzerland also recognizes the US Privacy Shield framework, along with the EU and UK. So there's EU-Privacy Shield (dead), UK-Privacy Shield, Swiss-Privacy Shield, EU-GDPR, and UK-GDPR. I had thought there was also Swiss-GDPR, but there is not.