The UK's exit from the EU has changed how EU Binding Corporate Rules (BCR) holders legitimise transfers of personal data from the UK. Post-Brexit, holders of EU and UK BCR had to create and maintain two separate versions of their BCR, which required extensive drafting work and long approval timeframes. However, the Information Commissioner's Office (ICO) has introduced a new process that allows organisations with approved EU BCR to submit a UK BCR addendum to extend the scope of their EU BCR to include data transfers from the UK. The new process, initially suggested by Hogan Lovells in collaboration with Privacy Laws & Business in January 2023, does not require a separate set of UK-specific BCR documentation and significantly streamlines approvals. The ICO has also created a draft template for the UK BCR Addendum to facilitate the process, which can be used as a standard form or guidance.
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