ICO publishes response to SEC’s request for guidelines on cross-border transfers and personal data disclosure
January 27, 2021
Akin Gump Strauss Hauer & Feld LLP
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In response to a request from the SEC, the UK Information Commissioner’s agent, the UK Data Protection Authority (ICO), has published a letter to the SEC setting out the ICO’s views on regulating relevant transfers of personal data that will help companies understand how you can comply with both your SEC obligations and the UK GDPR. A UK company is likely to be able to provide requested documents containing personal information by relying on the “public interest” exception in Article 49 (1) (d) of the UK GDPR. However, organizations need to verify that the submission is “necessary and proportionate”, provide information to customers and employees, and document their decision-making process. Click here for the full warning.
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