The ICO’s new streamlined approach to UK BCRs

The new system allows for a single version of EU BCR supplemented by a UK Addendum. By Eduardo Ustaran, Katie McMullan and Jabeen Rizvi of Hogan Lovells.

Following a re-think of the process for the authorisation of UK BCR after Brexit, the Information Commissioner’s Office (ICO) has devised a new mechanism to significantly streamline approvals. The new process, which was ­originally suggested by Hogan Lovells in collaboration with Privacy Laws & Business (see our memorandum, “Building a common EU and UK BCR framework” of 10 January 2023(1) following our joint workshop).(2) This suggestion, which has now been adopted by the ICO, allows organisations with approved EU BCRs to create and submit to the ICO a UK BCR addendum to their EU BCR which will extend the scope of the EU BCR to include data transfers from the UK.

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