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Standard Contractual Clauses (SCC’s) – End of Transition Period – Brexit
The transition period ended on 31st December 2020. The Government announced that the Treaty agreed with the EU will allow personal data to flow freely from the EU (and EEA) to the UK, until adequacy decisions have been adopted, for no more than six months.
The Information Commissioners Office recommend as a sensible precaution, before and during this period that businesses that work with EU and EEA organisations who transfer personal data to them put in place alternative transfer mechanisms, to safeguard against any interruption to the free flow to EU and UK personal data.
On the 19th February 2021 the European Commission published its draft decisions on the UK’s adequacy under the EU’s General Data Protection Regulation (EU GDPR) and Law Enforcement Directive (LED). In both cases, the European Commission has found the UK to be adequate.
The draft decisions will now be considered by the European Data Protection Board (EDPB) and a committee of the 27 EU Member Governments.
However, an adequacy decision is not guaranteed, and it has been widely recommended by various regulatory bodies and indeed Brokers Ireland that at a minimum, company’s ensure that GDPR appropriate safeguards in place, such as SCC’s with business partners to ensure business continuity. In being proactive MIS took steps to issue SCC’s ahead of the initial extension period expiration date April 2021. A further extension has now been agreed to end June 2020.
We would like to take this opportunity to explain that the SCC’s relate to our Breakdown Recovery Service in the Republic of Ireland. Whilst we endeavour to administrate this service from our local Irish office it may become necessary for overflow to be actioned by our Belfast Office. With the nature of this service, we wish to be in a position to assist customers quickly and efficiently.
MIS Underwriting Limited, Dundalk will continue to administrator all MIS Underwiring Insurance Products exclusively.
We would hope that the UK will receive the adequacy decision and the SCC’s will not be required, however we feel it is best to be prepared ahead of time.
