Background
At 23.00 (GMT) on 31 December 2020, the transition period agreed
under the Withdrawal Agreement between the EU and the UK expired.
From that point, Regulation (EU) 2016/679, (the
"
GDPR") ceased to have direct effect in
the UK. Whilst the UK has onshored much of the existing EU GDPR
legislation into UK legislation ("
UK
GDPR") the European Commission has not yet adopted an
adequacy decision in relation to the UK's data protection
regime.
As a result, any transfers of personal data from any EEA Member
State to the United Kingdom from 1 January 2021 onwards constitutes
a "third country" transfer which ordinarily requires EEA
data controllers and EEA data processors to implement certain