Our Take on the Proposed UK Data Protection Law Reforms

On the 10th September 2021, the Department for Digital, Culture, Media, and Sport (DCMS) released its proposal to reform UK Data Protection laws, called “Data: a new direction”. The document included removing the need for Data Protection Officers, records of processing activities, and data protection impact assessments. In its place is a concept of a more flexible, risk-based ‘privacy management programme’.

Listen to Regina Johnys provide an overview of some of the reforms that DCMS is proposing, including:

๐Ÿช Creating a ‘whitelist’ of situations in which the legitimate interest test would apply with having to conduct a balancing exercise, for example using analytical cookies.

๐Ÿ’ท Re-introducing a notional fee for subject access requests, and invalidating vexatious DSARs.

๐Ÿ‘ฉ๐Ÿปโ€๐Ÿ’ผ Implementing a Privacy Management Programme which will require you to define roles and responsibilities within your organisation with respect to data protection, in particular designating an individual responsible for the PMP

๐Ÿ“ demonstrate evidence and support from senior management; implementing processes to monitor and update the programme and check its effectiveness; implement measures to support the programme.

๐Ÿ—บ Making international data transfers of personal data from the UK to 3rd countries more “proportionate, flexible and interoperable”.

๐Ÿ‘” Changes to the role of the Information Commissioner’s Office will involve moving towards addressing the most serious threats posed to public trust.

This was a lively webinar, with a number of questions.

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