Client Alert: Upcoming UK and EU Data Transfer Deadlines

By: Faith D. Kasparian, Kevin S. Olson and Ryan J. Perry
September 22, 2022

Any companies handling UK or EU personal data must be aware of the following deadlines regarding international data transfers.

This past spring, the UK data protection regulator, the Information Commissioner’s Office released new standard contractual clauses for international data transfers. To remain in compliance with the UK data protection laws, most US-based companies must begin using these new UK standard contractual clauses in contracts entered into from and after September 22, 2022.

On a related note, there are two other deadlines looming for both EU and UK personal data transfers. For the EU, to the extent that companies had relied on the prior EU standard contractual clauses in legacy contracts for transfers involving EU personal data, all existing legacy contracts must be transitioned to the new EU standard contractual clauses by December 27, 2022. And, looking forward, all existing legacy contracts involving transfers of UK personal data entered into on or before September 21, 2022 must be transitioned to the new UK standard contractual clauses by March 21, 2024.

If you have questions about these deadlines or international data transfer, or about any other data protection matter, please contact Faith Kasparian, Kevin Olson, Ann O’Rourke, or Ryan Perry.

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