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.
19th August 2022
12:30PM - 13:30PM
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