At Vuture we have assessed our ability to provide services to you, our clients post-Brexit, and we have put contingency plans in place.
Under EU data protection law, transfers of personal data to recipients outside the European Economic Area (EEA) are considered to be transfers to a “third country” and therefore require “additional safeguards” to be put in place in order to ensure continued application of the EU’s data protection standards.
In the event of a ‘no deal’ Brexit, i.e. the UK leaving the EU without having a withdrawal agreement in place which contains provisions dealing with how data protection matters will be handled, the UK will become a “third country” for the purposes of EU personal data transfers.
The EU Commission has so far recognised Andorra, Argentina, Canadian commercial organisations, the Faroe Islands, Guernsey, Israel, the Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, the United States of America (within the Privacy Shield framework), and Japan as third countries which do provide adequate protection of personal data under Article 45 of the General Data Protection Regulation (GDPR). The effect of such recognition is that personal data can flow from the EEA to that third country without any further safeguard being necessary. It remains to be seen whether our government will negotiate a withdrawal agreement that includes this or whether we will have to work towards obtaining recognised third country status.
European Data Centre
In the meantime, Vuture has prepared a Data Centre in Europe (Frankfurt) which will allow any of our clients, who wish us to move their data into Europe, to do so. The contracts are prepared and ready to be implemented on demand.
Standard Clauses
We have prepared a series of standard contractual clauses which can be put in place, between us and our clients, to reflect our position in the event of a no deal Brexit.
Core Suppliers
We have reviewed our current contracts with our core suppliers and we are satisfied that both sides of the contracts are with UK-held companies and will not affect our ability to continue providing a service to our clients.
GDPR Compliance
We ensure that all our operations, both internally and for our clients, are GDPR-compliant. We continue to recommend best practice to all our clients to help them ensure an equal level of compliance.
Supporting our People
Infrastructure is not the only impact of Brexit. There are going to be significant human capital implications. We have mitigated that impact by hiring immigration specialists to assist our non-UK passport holding employees to ensure they have the adequate status necessary to weather any possible Brexit future and thereby ensure consistency in the delivery of services to all our clients.