Managing
Cross-Border Data Flows
The rules on transferring personal data outside the UK have become significantly more complex since Brexit. We help organisations identify their transfers, implement the right safeguards, and keep their documentation up to date as the adequacy landscape evolves.
International transfers need specialist attention
UK GDPR restricts transfers of personal data to countries that do not provide an equivalent level of protection. Since Brexit, the UK has operated its own adequacy framework, separate from the EU’s. Meaning organisations moving data between the UK, the EU, and third countries face a genuinely complex three-way analysis.
Many organisations do not realise how many international transfers they make. Cloud services, SaaS tools, offshore support teams and global parent companies can all create transfer obligations that are easy to overlook and expensive to get wrong.
UK IDTA vs EU SCCs
Following Brexit, the UK uses its own International Data Transfer Agreement (IDTA) for transfers from the UK to third countries. For transfers that also involve EU personal data, the EU’s updated Standard Contractual Clauses (SCCs) apply.
Many organisations with UK and EU operations need both. The documentation must be kept separate and up to date, as adequacy decisions change.
Transfer Impact Assessments
A TIA is required where you cannot rely on adequacy alone. Typically, for transfers to the US, India, China and other countries, where surveillance laws create a meaningful transfer risk.
We produce documented TIAs that reflect the legal environment in the destination country, not a generic format.
International Transfer Coverage
United States
The UK-US Data Bridge provides a mechanism for transfers to certified US organisations. We assess whether certification is genuine, document the transfer basis, and advise where the bridge cannot be relied upon.
Asia-Pacific (APAC)
Transfers to Singapore, Australia, Japan, India and other APAC countries require careful analysis. We assess local data protection laws against the UK standard and produce TIAs where required.
Middle East & Africa (MENA)
MENA-region transfers are a growing source of complexity for our fintech and aviation clients. We provide jurisdiction-by-jurisdiction analysis and appropriate documentation.
UK–EU flows
The EU’s adequacy decision for the UK is not permanent. We keep clients informed of developments and ensure their documentation remains valid if the adequacy were to be withdrawn.