Memo to the Minister 2

03 October 2022

Norton Rose Fulbright, London


Roundtable for companies and their advisors to be briefed by the DCMS policy team on the International Data Transfers parts of the UK Data Protection and Digital Information Bill.

Date: Monday 3 October 2022
Times: 09.30 to 15:00
Location: Norton Rose Fulbright, London
CPE Credits: up to 4

This event will provide insights into both the government’s strategy and the ways that the DCMS team is conducting discussions with counterparts across the world to fulfil its aim of an independent international data policy. The output will be the participants’ feedback and constructive comments to Julia Lopez MP, the DCMS Minister, at this crucial period when the Bill is expected to start its passage through Parliament.

There is a balance to be struck between making the most of Brexit opportunities and risking the UK’s valuable EU adequacy declaration. To what extent will UK policy decisions lead to UK diversion from compatibility with the EU GDPR?

This interactive Roundtable will provide you with your best opportunity to receive an update from DCMS policy advisors on how they are forging an independent UK international data policy so you can review the legal basis for your data transfers to different jurisdictions accordingly. With the government’s promise of announcements on data transfer agreements with the Top 10 jurisdictions by the end of 2022, you can expect to learn both about the big picture and progress on delivering agreements with specific jurisdictions.



Roundtable Programme

09.30 Registration and Coffee

Framework for assessing adequacy of third countries

  • UK Policy approach and rationale for assessing adequacy
  • Assessing adequacy under the current UK regime using the UK Manual Template and Manual Guidance versus the EU WP29/ EDPB referentials and the EU process
  • The DCMS’s relationship and ways of working with the ICO and Parliament on adequacy



Specific updates under the UK’s adequacy programme

  • Update and reflections on ongoing assessments and priorities
  • Reflections on wider global trends and developments
  • Relationship with the EU and EU-UK adequacy
  • Relationship between this exercise and the countries included in the International Free Trade Agreements concluded since 2019
  • Which narrower adequacy findings are contemplated: for example, by state, by sector, by specific recipient

Other international initiatives

  • DCMS’s view of, and participation in, APEC and Global Cross-Border Privacy Rules
  • DCMS’s views on other multilateral and international initiatives (e.g. OECD work on Trusted Government Access to Data)
13.15 Lunch after which the DCMS and ICO participants depart

Confidential exchange of practical experience

Raise the issues which concern you. For example:

  •  Have any of your international transfers been suspended? (e.g. Google Analytics)
  • Experience of carrying out any Transfer Impact Assessments?
  • Which non-adequate countries do you worry about apart from the US?
  • Are you using Standard Contractual Clauses?
  • Have you used or are you planning to use Binding Corporate Rules?
  • Which other export regimes are you dealing with which pose difficulties?
15:00 Close
Output from the Roundtable


The speakers are DCMS policy advisors who have worked on developing government policy and will advise the minister, including:

  • Joe Jones, Deputy Director - International Data Transfers, Data Policy Directorate
  • Siddharth Bannerjee, Head of Europe Data Transfers Strategy & Expert Council, International Data Transfers
  • Adriana Mara, Europe Strategy Adviser, International Data Transfers
  • Ryan Jones, Senior Policy Adviser, International Data Transfers Reform

Thanks to our host