A recent enquiry about Article 27 Representation
We recently had an enquiry from a client who runs an international business across 30+ countries, their enquiry was about GDPR compliance and they also wanted to know what the impact of a no-deal or even a limited deal Brexit would have on their European business operations.
Here, David Fagan shares his response…
Thank you for your enquiry. The Article 27 service provided by eurep.ie comprises holding your Article 30 record (as set out by you in the signup process), appointing us as your Article 27 EU Representative, providing you with wording to comply with your transparency obligations under Article 12, 13, and 14 with regard to the notification of EU Rep as your Article 27 Representative, and the execution of a Controller – Processor Agreement in conformity with Article 28.3.
In essence you appoint us as your EU Representative, and notify your Data Subjects of that appointment, and we notify you of any queries or complaints from Data Subjects, or from EU Data Protection Authorities.
In the event of a complaint, or query, we advise in very broad-brush terms and provide you with a quote for additional services, such as responding to the query on your behalf, translation of documents, defence of legal claims et cetera. Separately, our sister company Business Legal can assist you with all of your bespoke GDPR needs.
In the event of a no–deal Brexit, or possibly even in the event of a limited deal, you will be required to take steps to legitimise the transfer of personal data from the EU. The most likely solution for you will be the use of Standard Contractual Clause (Model Clause) Agreements, and you may also require to put in place Controller – Processor Agreements with your Processors (if you are a Controller) or your Controllers may require to put in place Controller – Processor Agreements with you (if you are a Processor). You will also require your processing to be in conformity with GDPR. We can assist you with this through audits and remediation of your processes and policies.
We can assist you with all matters. However the Article 27 Representative service itself extends only to our appointment as your Representative, the notification to you of any queries or complaints from Data Subjects or Regulators, and putting in place of necessary agreements and wording to comply with Articles 12, 13, 14, 27, 28.3 and 30 in respect of our appointment.
This is why the Article 27 service can be priced so competitively. All other services are however competitively priced also, and our sister firm Business Legal can assist you in all areas of GDPR compliance.