The UK and the US have recently signed a new agreement which covers various aspects of trade cooperation, setting out a series of sector-by-sector agreements on several matters, including AI regulation, electric car manufacturing, the recognition of professional qualifications, defence procurement and data protection alignment.
Discussing the data protection implications of this agreement, Adam Rose, Partner and Chair of the IBA Data Protection Governance and Privacy Subcommittee explained that while Brexit allowed the UK to form its own trade and data agreements with third countries, the "reality has been that, for the UK to maintain its trade relationship with the EU, it needs to remain broadly aligned with the EU's approach to data transfers to third countries, including – in particular – with the US. The data provisions of the Atlantic Declaration are an illustration of this: they come hot on the heels of the European Commission’s recent draft adequacy decision in relation to the US,’ which concluded that the US ensures an adequate level of protection – comparable to that of the EU – for personal data transferred from the EU to US companies under the new data privacy framework between the two jurisdictions."
Read the full article on the International Bar Association's website.