What does IP completion day mean for Information Law?
What does IP completion day mean for Information Law?

The following Information Law practice note provides comprehensive and up to date legal information covering:

  • What does IP completion day mean for Information Law?
  • Overview—what happened on 31 December 2020
  • Access to EEA workers
  • Commercial arrangements
  • Data protection
  • Regulatory regimes
  • Potential exposure to separate UK and EEA data protection regimes
  • International transfers of personal data
  • Representatives
  • Updates to documentation and records
  • More...

11 pm (GMT) on 31 December 2020 marked the end of the implementation period put in place to enable the UK to transition away from the EU’s laws and institutions. At this point in time (referred to in this document as ‘IP completion day’) there was an immediate and significant change in the UK’s legal regime. This Practice Note explains the implications of this change in relation to the following areas of Information Law and practice:

  1. Overview—what happened on 31 December 2020

  2. Access to EEA workers

  3. Commercial arrangements

  4. Data protection (except as relevant to law enforcement processing and intelligence services processing)

  5. ePrivacy

  6. Cybersecurity

  7. Databases

  8. Public sector information

  9. Confidential information

  10. Reputation management

For a tracker of key Information Law Brexit legislation and guidance, see Practice Note: Information Law—Brexit tracker.

This Practice Note focuses on the topics above, except that it does not cover the impact on law enforcement processing or state security or intelligence operations.

Overview—what happened on 31 December 2020

On 31 January 2020 (‘exit day’), the UK ceased to be an EU Member State and lost its entitlement to participate in the political institutions and governance structures of the EU. In accordance with the transitional arrangements provided in Part 4 of the Withdrawal Agreement, exit day marked the commencement of an 11-month implementation period during which the UK continued to be treated by the EU as a Member State for

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