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On December 17, 2020, the UK Information Commissioner’s Office (‘
ICO’) published its Data Sharing Code of Practice (the ‘
Code’) following a public consultation which commenced in 2019. The Code focuses mainly on data sharing among data controllers who are subject to the GDPR and the UK Data Protection Act (‘DPA’) 2018. Data controllers falling within the scope of the ICO’s enforcement powers should take the Code into account when sharing personal data because it will help them comply with their data protection obligations. Due to the detailed way in which the Code covers data sharing in the context of the GDPR, it will also be of wider interest to data controllers in the EU and beyond – even after the end of the Brexit transition period.
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Since entering into force in May 2018, the EU General Data
Protection Regulation (GDPR) applies to all entities in the
European Economic Area (EEA) and - due to the extended territorial
scope - to a large extent also to entities outside of the EEA. The
GDPR has led to a significant rise in data protection compliance
duties. In case of violations, companies may face fines of up to 4%
of the global annual turnover of the whole company group.
Supervisory authorities do not seem to be afraid to push those