Brexit Transition: How-To-Prepare Guide for Northern Ireland and Personal
Data Flows from the EU
New business rules start on 1st January. If you are a business or organisation based
in Northern Ireland which receives personal data from the EU or EEA, including the
Republic of Ireland, you need to act now in order to keep personal data flowing in
line with new rules.
This guide highlights some of the most important actions to take. For further
guidance, access our Transition Checker for a personalised list of actions.
1. Introduction
Personal data is defined as any information that can be used to identify a living
person, including names, delivery details, IP addresses, or HR data such as payroll
details. Most organisations use personal data in their daily operations. The rules on
personal data are the same in all nations across the UK, including Northern Ireland.
The EU is conducting a data adequacy assessment of the UK including Northern
Ireland. If the EU grants positive adequacy decisions by 1 January 2021, it would
mean that personal data can flow freely from the EU/EEA to the UK, as it does now,
without any action by organisations.[BG1]
There are no changes to the way you send personal data. If this situation changes,
we will update this guide.
For international data transfers from the UK to other jurisdictions, further information
can be found on the ICO’s website.
It is important that Northern Ireland businesses and organisations act now to
ensure that personal data can continue to flow lawfully from 1st January.
2. Actions to take now
There are six actions you can take now to prepare for a no data adequacy decision
from the EU:
1. Understand whether your business has personal data flowing from the EEA,
including the Republic of Ireland
2. Understand who is transferring the data
3. Discuss with the EEA business counterpart the best alternative transfer
mechanism to adopt in order to maintain this data flow, for example, standard
contractual clauses
4. Ensure Alternative Transfer Mechanisms are agreed with your EU
counterparts and are put in place, by 1 January 2021. For further information
go to the Information Commissioner Office (ICO) website which has a section
on preparing for the end of the transition period on this page
5. Sign up for the ICO newsletter for up-to-date information
6. Check out more information on personal data available on gov.uk