United Kingdom. Data localisation / cross-border. Statutory instrument (SI 2023/1028)

UK–US Data BridgeData Protection (Adequacy) (United States of America) Regulations 2023 – UK Extension to the EU–US Data Privacy Framework ('UK–US Data Bridge')

In force
Partly verifiedMedium confidence. Status depends on continued operation of the EU–US DPF and PCLOB/EO 14086 safeguards; monitor US developments.

§1Summary

Synopsis

UK adequacy regulations allowing personal data to flow to US organisations certified to the UK Extension of the EU–US Data Privacy Framework without further safeguards. It depends on the US Executive Order 14086 redress mechanism being extended to the UK.

Key themes
  • adequacy
  • DPF certification
  • US redress
  • onward transfers
Unique features

Excludes some data (e.g. journalistic data) and requires explicit flagging of special category data by exporters such as genetic, biometric and criminal data.

SaaS relevance

A UK SaaS provider can use US vendors certified to the UK Extension without an IDTA; US SaaS providers can self-certify to receive UK data.

§2Obligations

Cross-border transfers
Partial adequacy for certified US organisations

§3Dates

Key dates
  • Adopted
  • In force

§4Text and authority

Text
Authority
Information Commissioner's Office (ICO); DSIT

§5Where it applies

Domestic law of
United Kingdom

§6Sources and verification

Sources consulted
Verification

Medium confidence.

Partly verifiedMedium confidence. Status depends on continued operation of the EU–US DPF and PCLOB/EO 14086 safeguards; monitor US developments.