Hogan Lovells has published their submission to the ICO's public consultation on proposals around revisions to UK guidance and processes for international data transfers. "Our contribution is based on both our interpretation of the UK GDPR and our experience advising clients in this area, and it takes into account the legislator's intention as well as the jurisprudence of the CJEU as applicable to UK law." The law firm specifically commented on the ICO's plan to update data transfer guidance, a proposed transfer risk assessment tool, and model transfer agreements.
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