Data Strategy Briefing — September 21, 2023
The UK Government approved the UK-US data bridge, extending adequacy to certified U.S. organisations under the Data Privacy Framework and simplifying cross-Atlantic transfers.
Executive briefing: On 21 September 2023 the UK Government confirmed the UK-US data bridge, recognising the U.S. as providing adequate protection for personal data transferred to organisations certified under the Data Privacy Framework. The decision, effective 12 October 2023, allows UK organisations to rely on certified U.S. partners without additional transfer risk assessments or standard contractual clauses.
Key governance checkpoints
- Certification verification. Validate that U.S. recipients appear on the Department of Commerce Data Privacy Framework list with UK extension coverage.
- Transfer inventories. Update records of processing and transfer registers to reflect data bridge reliance and fallback safeguards.
- Accountability documentation. Retain evidence of due diligence, privacy notices, and contract updates reflecting the adequacy mechanism.
Operational priorities
- Vendor governance. Incorporate monitoring of certification renewals and complaint handling obligations set by the UK Information Commissioner’s Office (ICO).
- Data subject communications. Update transparency notices to reflect the UK-US data bridge and available redress routes.
- Fallback planning. Maintain alternative safeguards—such as IDTAs or SCCs—in case certification lapses or scope changes.
Enablement moves
- Coordinate with U.S. partners on compliance with the Data Privacy Framework principles, including onward transfer controls and dispute resolution.
- Monitor ICO guidance and periodic reviews of the adequacy decision to anticipate potential changes.
Sources
Zeph Tech helps UK organisations operationalise the data bridge through transfer register updates, certification monitoring, and fallback safeguard planning.