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UK GDPR post-Brexit divergence — data transfers to EU processors after 2025 adequacy review
The UK's adequacy decision from the EU is up for review. If adequacy is withdrawn, UK-based companies would need SCCs or another transfer mechanism for EU personal data. Article 45 UK GDPR currently mirrors EU GDPR Art. 45, but the ICO has signaled potential divergence on children's data and automated decision-making. Are organizations already preparing contingency transfer mechanisms (SCCs, BCRs) in case adequacy is not renewed? What's your fallback position?
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