Implications of Brexit on Dun & Bradstreet Data
Implications of Brexit on Dun & Bradstreet Data
Frequently Asked Questions for all products and services
In March 2019 it is likely the United Kingdom will leave the European Union (EU). The EU classes the business data Dun & Bradstreet process on individuals in their business capacity as “personal data” and regulates the flow of this data out of the EU. As a global company, Dun & Bradstreet manages business data relating to individuals across many jurisdictions and is fully prepared for any legal changes that will occur as a result of the UK’s departure from the EU. Customers can be assured that we have taken all appropriate steps to ensure it will be lawful to transfer and receive personal data from Dun & Bradstreet.
1 Will my business have to take any action because of our relationship with Dun & Bradstreet post Brexit?
No. As the global leader in commercial data and analytics, we understand how to protect data. This note explains the actions we have taken to ensure our relationship can continue post Brexit.
2 Will Brexit have an effect on my order with Dun & Bradstreet?
If you use D&B for insight into businesses registered in the EU, your business will be transferring EU personal data (as defined in the GDPR) to us in order to receive our products and services. The EU has strict regulation about the transfer of EU personal data. Our service will not be disrupted as we have already taken the necessary steps to comply with this regulation.
3 How does Brexit have an effect on my order with Dun & Bradstreet?
Personal data can be transferred between EU member states without any restrictions. When the UK leaves the EU it will no longer be considered as a member state and therefore restrictions will apply.
Post Brexit, it will still be possible to freely transfer personal data from the UK to the EU. However, transfers from the EU to the UK will be regulated in the same way transfers from the EU to other non member states (such as Australia or India) are and “safeguards” are necessary to ensure the transfer is lawful. Safeguards are obligations the data exporter and importer enter into to ensure EU personal data is maintained to GDPR standards.
4 What safeguards do D&B use?
There are several forms of safeguards available for businesses to use and Dun & Bradstreet considers data transfer agreements are the safest and most appropriate safeguard to use. So to ensure customers can continue to transfer EU personal data to us, we include a data transfer agreement within our contractual framework. The clauses in the data transfer agreement are stipulated by the EU Commission and cannot be amended by either party. This agreement provides the necessary commitments to ensure EU personal data can be lawfully transferred from customers to the United Kingdom post Brexit.
5 Where is the Data Transfer Agreement found?
Dun & Bradstreet’s data transfer agreement can be found at schedule 3 of the “D&B Data Processing Agreement” at www.dnb.co.uk/dpa. Our data processing agreement applies whenever a customer provides us with EU personal data. FAQs on D&Bs Data Processing Agreement can be found here. This agreement is incorporated into our contractual framework through our Master Agreement and Order forms.
6 Does the data transfer agreement put obligations on my business?
Yes but only ones you will already be meeting for EU personal data under the General Data Protection Regulation (GDPR).
7 Does the data transfer agreement put obligations on Dun & Bradstreet?
Yes and these are aligned to the obligations we commit to in our data processing agreement.
8 Does my business need to sign the data transfer Agreement?
Customers agree to the Data Transfer Agreement through signing the Order Form and Master Agreement. No separate signature is required.
9 Does Dun & Bradstreet use third parties based in the remaining EU states to process my data?
Yes. As a global company we use carefully selected and stringently monitored sub processors based around the world to provide our world class service. A list of our sub processors can be found in the D&B Data Processing Agreement. We use lawful transfer mechanisms to transfer EU data to these processors in accordance with the GDPR and the Data Protection Act 2018.
10 What about protection of UK data?
Dun & Bradstreet protects all data. The GDPR has been incorporated into UK law so we will continue to apply the same standards to our UK data post Brexit. Under UK law we will be able to continue to transfer data to the remaining EU states as we do today. Therefore, the only change in relation to cross border data transfers is from the EU to the UK. We will continue to observe all restrictions on transferring UK personal data to non EU member states.
11 Will political events in relation to a Brexit deal alter Dun & Bradstreet’s continuity plan?
Our Brexit preparations have been formulated to ensure security for our customers and will provide continuity regardless of any deal that is made. Please ask your relationship manager for the most up to date version of this FAQ.
This information is specific to Dun & Bradstreet and is not provided as legal advice. Customers should rely on their own legal advisors for how Brexit will affect their business generally.
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