Google plans to move UK users' accounts outside EU jurisdiction
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Re: Google plans to move UK users' accounts outside EU jurisdiction
#2Previously posted and discussed here: https://news.ycombinator.com/item?id=22370405
Re: Google plans to move UK users' accounts outside EU jurisdiction
#3I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK.
Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than trying to deal with the exceptions.
Re: Google plans to move UK users' accounts outside EU jurisdiction
#4I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than tryi…
Why would that be necessary?
Re: Google plans to move UK users' accounts outside EU jurisdiction
#5I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than tryi…
i think the stronger data protection would prevail for NI
Re: Google plans to move UK users' accounts outside EU jurisdiction
#6I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than tryi…
> British law also N.Irish people to declare themselves Irish under the GFA
This by itself doesn't mean anything for GDPR—GDPR applies to EU residents (whether or not they are EU citizens), not EU citizens. Declaring yourself Irish doesn't make you fall under GDPR protection if you live outside the EU.
Re: Google plans to move UK users' accounts outside EU jurisdiction
#7It is real. I just got an email about this from Google about my gmail account:
- Your service provider and data controller is now Google LLC: Because the UK is leaving the EU, we’ve updated our Terms so that a United States-based company, Google LLC, is now your service provider instead of Google Ireland Limited. Google LLC will also become the data controller responsible for your information and complying with applicable privacy laws. We’re making similar changes to the Terms of Service for YouTube, YouTube Paid Services and Google Play. These changes to our Terms and privacy policy don’t affect your privacy settings or the way that we treat your information (see the privacy policy [link redacted] for details). As a reminder, you can always visit your Google Account https://myaccount.google.com > to review your privacy settings and manage how your data is used.
Re: Google plans to move UK users' accounts outside EU jurisdiction
#8I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than tryi…
Why would that be necessary?
Because unless the UK and the EU reach a trade agreement by the end of the year, the provisions of the Withdrawal Agreement kick in and Northern Ireland becomes bound to EU regulation.
This is a long and complicated story, but essentially Brexit created the following problem: the UK now desires to have full control over its borders, and this means a hard border between the UK and the EU. But then there is also the Good Friday Agreement (GFA), which achieved peace between the unionists (Protestants who want NI to be part of the UK) and the nationalists (Catholics who want NI to be part of Ireland). Simplistically, the GFA guarantees a sort of double affiliation of NI, both to the UK and to Ireland. This means, among other things, no physical borders.
Re: Google plans to move UK users' accounts outside EU jurisdiction
#9I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than tryi…
> British law also N.Irish people to declare themselves Irish under the GFA This by itself doesn't mean anything for GDPR—GDPR applies to EU residents (whether or not they are EU citizens), not EU citizens. Declaring yourself Irish doesn't make you fall under GDPR protection if you live outside the EU.
I am not sure if this entirely true. My understanding was it was both citizens and residents.
Re: Google plans to move UK users' accounts outside EU jurisdiction
#10I would imagine N.Irish users might end up being covered by GDPR -- British law also N.Irish people to declare themselves Irish under the GFA. N.Ireland could well end up with a special status post-Brexit where it's both in and out of the EU and in and out of the UK. Given European data protection is much stronger than either British or American DP it would make sense to group N.Irish people this way rather than tryi…
> British law also N.Irish people to declare themselves Irish under the GFA This by itself doesn't mean anything for GDPR—GDPR applies to EU residents (whether or not they are EU citizens), not EU citizens. Declaring yourself Irish doesn't make you fall under GDPR protection if you live outside the EU.
GDPR applies to EU citizens globally. It's just not enforced globally. The company will have to be large enough to have a presense (or future presense) in the EU for there to be an tangible impact.
>Declaring yourself Irish doesn't make you fall under GDPR protection if you live outside the EU.
I'm a DPO and this is absolutely incorrect.