Industry codes take a great deal of time to agree first within a sector and then with the Data Protection Authorities whether at UK or EU levels. In the UK, the ICO’s Children’s Code took several years to develop.

In a session on 24 March at the IAPP UK Intensive in London, a panel discussed the EU Cloud Code of Conduct. This sector is central to the digital economy. Could the code be adapted for the UK, now outside the European Economic Area? In theory, the cloud sectoral code is designed to ensure and prove that GDPR compliance for all types of cloud computing could be regulated in the same way across Europe. While the UK was in the EU, the rules would have been identical. But now the code would have to be reviewed in detail to assess its compatibility with the UK legal regime.