Recent decisions by EU Data Protection Authorities have caused upheaval for businesses using tools such as Google Analytics, which share personal data collected through cookies with data importers in third countries like the United States. This article looks at the potential impact of this upheaval from a UK ­perspective.

The position in the EU

Schrems, NOYB and 101 Complaints: Max Schrems’ complaint about Facebook’s overseas data transfers culminated in the so-called Schrems II judgment (Case C-311/18). Schrems’ non-profit organisation (“NOYB”) has since focused on cookie compliance, bringing 101 complaints against organisations across the European Economic Area (the “101 Complaints”) shortly after the judgment in Schrems II.