On January 9, the EU Commission issued a notice on the potential implications of Brexit for transfers of personal data to the United Kingdom. From the date of Brexit, the United Kingdom will become a "third country," and the adequacy of its protections for personal data will need to be assessed by the EU Commission. However, the notice states that even if an adequacy decision is not granted, data flows need not be unnecessarily interrupted, as other options (such as model clauses, binding corporate rules, and exceptions such as contractual necessity) will remain available.

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