How data privacy compliance obligations shift depending on the direction of data flow involving the UK, EU, and non-EU/UK (third) countries. Since Brexit, the UK operates under its own version of GDPR (UK GDPR), which diverges from the EU GDPR in subtle but important ways.

1. EU to UK Transfers:

• What are the current legal mechanisms for EU entities to transfer personal data to the UK?
• What is the status of the UK’s adequacy decision under the EU GDPR?
• Are there any risks or considerations for EU businesses when dealing with UK data processors or controllers?

2. UK to EU Transfers:

• Does the UK recognize the EU as adequate?
• Are there any formalities required for UK entities transferring data to the EU?
• How do UK GDPR and EU GDPR expectations align or differ in this scenario?

3. UK to Third Countries & Vice Versa:

• How does the UK determine adequacy for non-EU countries (e.g., India, US, etc.)?
• What transfer tools (e.g., SCCs, IDTA) are recognized under UK GDPR?
• If you're a business based outside the UK receiving data from the UK, what must you consider under UK GDPR?

4. Third Countries to EU Transfers:

• What obligations do third countries have under EU GDPR when receiving EU data?
• How does this relate to the concepts of adequacy, safeguards, and data subject rights?
• If a company operates across all three jurisdictions (EU, UK, and another third country), how do they ensure compliance simultaneously?