By Piers Larbey

Important Information if you plan to offer goods and services to individuals in the EEA after the transition period has ended.


The UK left the EU on 31 January 2020 and the transition period is due to end on 31 December 2020. During the transition period the existing GDPR framework has continued and it is the UK's intention that the GDPR framework will be retained in the UK at the end of this period.

However, if you are a business based in the UK and you plan to offer goods or services to individuals in the EEA (the EU plus Iceland, Norway and Liechtenstein), after the end of the transition period you will need to comply with the EU data protection rules as well as GDPR in the UK.

It is to be expected that the EU data protection rules will require you to appoint a representative based in the EEA to act as your local representative in the EEA. There are various rules that govern the appointment of your representative in the EEA and these should be documented in a written agreement between you and your representative.

Once you have appointed your representative in the EEA you will need to ensure that details of the representative are made available to EEA individuals to whom you are offering goods or services. This can be done by updating your privacy policies or other terms and conditions that apply when you collect data.

We would encourage all businesses that may be affected by the new rules to act now and take advice on what action they may need to take regarding their ongoing data protection obligations both in the UK and the EEA.

11 December, 2020
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