Updated October 2025.
Brexit reminder. The UK left the EU and the Withdrawal Agreement was implemented on January 31st 2020. The UK-EU Trade and Cooperation Agreement (“TCA”) came into force on May 1, 2021.
Irish companies transferring personal data to the UK were primarily impacted from the 31st January 2020 to 1st May 2021.
Irish companies who were transferring data to a UK-based company had to consider whether they did the following:
- Outsourcing HR, IT or Payroll function to a UK based organisation.
- Using online tools that may be sited in the UK,
- Using a UK based marketing company to send marketing communications to your customer database?
- Used a pension scheme or scheme administrator based in the UK?
- Using a UK based company to analyse data on visitors to your website?
- Storing data in the UK on a server or in the cloud?
They needed to put extra measures in place to legally transfer data once the UK left the EU on January 31st 2020.
EU based data controllers are not permitted to transfer personal data outside the EU/EEA unless certain standards are maintained.
The UK is no longer a member of the EU; instead, it is a ‘Third Country’. It has received via the TCA a so called ‘Adequacy Ruling’ from the European Commission.
This means that transfer of personal data from Ireland to the UK is now treated in the same way as transfers of personal data to the EU.