| Commentary

(3) Legacy data

| Commentary

(3)     Legacy data

Employers holding any non-UK EU data collected before 1 January 2021 (referred to as 'legacy data') were for the period from 1 January 2021 until 27 June 2021 subject to what is known as 'Frozen GDPR' in respect of that data. Frozen GDPR is the term used to describe the EU GDPR as it stood on 31 December 2020. This was agreed as part of the Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community (EU-UK Withdrawal Agreement) to ensure that there

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