The simple answer is that, per Articles 4 and 7 of the Withdrawal Agreement, UK is to be treated as a Member State until the end of the Implementation Period, so transfers between U.K. and EU27 to continue as normal until then.
The more complicated answer makes my head hurt, and is probably only one of academic interest. If I change my mind on that I’ll post something soon.
Sent from my iPhone
> On 22 Jan 2020, at 13:42, Darren Davies <[log in to unmask]> wrote:
>
> Thanks everybody for the guidance thus far.
>
> I am sure I am not the only one with further questions around the exit plans. My question relates to SCC's, will we not need to consider using these until 31 December 2020? I know we could use these at any time but it seems they will not be the patch needed until after December 2020?
>
> Any thoughts on this?
>
> Regards
>
> Darren Davies | Data Protection Officer
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