21/03/22 – As expected, the International Data Transfer Agreement (IDTA), as well as the Addendum to EU SCCs, came into force today as appropriate safeguards for transfers of personal data from the UK to third countries under Article 46 of the UK GDPR. As part of the transitional arrangements the old EU SCCs (with appropriate modifications to make them ‘work’ for UK exporters) can continue to be used as an appropriate safeguard until 21 September 2022 and, if the processing remains unchanged, are capable of remaining valid until 21 March 2024. If you’re not sure what I’m talking about, have a look at my 01/02/22 update.
We are still waiting for the ICO to publish a final version of their new Transfer Risk Assessment (TRA) precedent and tool. In the meantime prospective exporters’ best bet is like to be to use the draft version from the ICO’s consultation last year. More information about TRAs here. I will you keep you updated.