Join us on the 19th of August for a discussion on data protection in the financial sector. Our amazing host Oliver Rear will be joined by Jason Ellis who is a long-time contributor and a well know data protection officer from Azets.

During this discussion we will cover the following:

• Complex Relationships and making the determination:

• Within a group:

• Which entities are controllers in a complex ownership structure involving hundreds of legal entities?
• Which of them employ staff?
• Which of them are just “holding companies?
• What about Licensed Insolvency Practitioners?
• The challenge of remaining compliant when Merger and Acquisition is a constant norm, not just once in a lifetime.

• With customers:

• Controller or processor when delivering services – with particular focus on payroll bureau services.
• Controller or processor, qualified accountant or bookkeeper, where is the boundary?

• As a segue to talking about contracts, within the context of complex relationships:

• EU representatives and UK representatives.
• Depending on time we might also talk about the below but we might struggle to fit them in:

• Outsourcing, offshoring and nearshoring. The challenge when the supplier is in a “third country”
• Employees wishing to work permanently from home, but in a foreign country, possibly a “third country”

• Contracts:

• Issues with “domestic” contracts (or at least contracts where internationalisation is not an issue:

• How to align Letters of Engagement, Data Processing Agreements and Data Sharing Agreements without causing contradictions.
• How to write appropriate contracts for software distribution and licensing when a group company owns the software IP but is used by thousands of clients and employees of the business.

• Moving between domestic and international:

• Intra-group data sharing agreement and SCCs, particularly when one entity is in the UK and the remainder are in the EU.

• International contracts:

• Impact of Brexit on contractual definitions in cross-border contracts.

• To close the loop we can go from the complexity of the above to the overall challenge of managing processors:

• How to keep the Register of Processors up to date when new processors are added almost daily. The importance of thorough vendor due diligence.