As Covid-19 restrictions are lifting and we look ahead to what the next six months or so may look like, it has become clear that Brexit-related issues need to return to the fore. Discussions at various political levels are intensifying but, until now, progress has been slow, with the UK and the EU still at odds on a number of key points. Given it has been formally confirmed that there will be no extension to the transition period beyond 31 December 2020, businesses therefore need Brexit strategy and plans.

From a data privacy perspective, much of the attention to date has focused on the likelihood of an adequacy decision to enable the free flow of data between the EEA and the UK. Whilst this is important given the amount of personal data that currently flows freely, there are other Brexit-related data privacy issues that have received less attention which also need to be addressed in the coming months. A number of these are considered below.