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Legal & compliance hub

This page contains all the information you need to understand how we engage with you, our customers and users. Please contact us at info@egress.com if you have any questions.

Legal and compliance hub

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Brexit

We are conscious that we are getting close to the end of the Brexit Transition Period and that our customers and users may have questions around what happens next and so to try and help, we’ve created this page to provide some insight into what we’ve been doing, and are continuing to do, as we now get ready for the UK’s final departure from the EU and other European institutions.

Does Egress consider the end of the Brexit Transition Period to be a risk?

We do not consider the expiry of the Brexit Transition Period to be a risk to our business model or the continued delivery of our services to our customers and users.

During the Transition Period there has been a maintenance of the status quo in many respects.  Until 11pm on 31 December 2020 the UK continues to remain in the EU’s single market and customs union, but none of the decision making bodies. 

We continue to monitor the steps and approach of the UK Government, the EU negotiators, and guidance from the Information Commissioner’s Office (ICO) and other European Data Protection Regulators.  We remain mindful of the potential for a return to concerns around a ‘no deal Brexit’ over the next 8 weeks depending on how the negotiations between the UK and the EU progress over the coming weeks.

What has Egress been doing to prepare for expiry of the Brexit Transition Period?

Since late-2018 we have been monitoring the discussions between the UK Government and the EU. In line with guidance from the Information Commissioner’s Office (ICO), we made preparations based on a ‘no deal Brexit’ during the uncertainty in 2019.

A key part of our preparations was to review our supplier contracts to make sure they contain legal mechanisms to comply with the requirements caused by a ‘no-deal Brexit’.

We also updated our privacy policies to refer to the UK territories as well as the EEA where this is relevant to the processing activities that we carry out in respect of personal data. You can see more on these at our Legal Hub here.

Does Egress use any sub-processors to process personal data outside of the UK?

Yes. You can find details of the sub-processors involved in delivering our services at www.egress.com/subcontractors. Some of these sub-processors may use data centres that are located outside of the UK (e.g. in either the United States or the EEA).

How will transfers of personal data between the UK and the EEA using Egress services be permitted after expiry of the Brexit Transition Period?

During the last weeks of 2020, the UK and EU will remain in a transition phase during which a status quo will be maintained in many respects, there will be no noticeable impact on transfers of personal data during these last weeks of the Brexit Transition Period.

We continue to monitor the steps and approach of the UK Government, the EU negotiators, and guidance from the Information Commissioner’s Office (ICO) and other European Data Protection Regulators.  We remain mindful of the potential for a return to concerns around a ‘no deal Brexit’ over the next 8 weeks depending on how the negotiations between the UK and the EU progress over the coming weeks.

How will transfers of personal data between the EEA and the United States using Egress services be permitted after expiry of the Brexit Transition Period?

Our supplier contracts already contain mechanisms to lawfully permit transfers of personal data outside of the EEA to the US where required to deliver our services to our customers and users in accordance with our Service Privacy Policy here.  You can find details of the sub-processors involved in delivering our services at www.egress.com/subcontractors.

Is there anything I need to do with Egress to prepare for expiry of the Brexit Transition Period?

If you’re an EEA/EU-based customer, or your use of our services includes the transfer of personal data from the EEA to the UK, then we also ask that you make sure that before 31 December 2020 you have signed our DPA which can be found here under Additional Service Terms. This ensures that we have signed the EU’s Standard Contract Clauses with you to lawfully permit these transfers after expiry of the Brexit Transition Period.

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