It's time for UK businesses to get creative in dealing with Brexit and all its uncertainties. As I've explained here, the processing of personal data relating to EEA residents is a particular problem. The UK is 13th on the list of countries that will be waiting for the European Commission to declare the UK personal data regime to be 'adequate' to transfer that data as of right (as happens now).
So, rather than bring personal data into the UK from the EEA, you could - as many already
have - simply incorporate an entity within the EEA to hold the data and
determine the means and purposes of processing there. That EEA entity could do
the processing itself within the EEA or outsource that to an EEA-based processor with the right experience and expertise. Ireland, for example, is the top AI hub in the EU and it can be a simple matter to transfer existing English law contracts to a new entity there, particularly as Irish law is so similar.
Only the aggregated results would need to come in to the UK.
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