Context Since Brexit, the UK GDPR diverged slightly from the EU GDPR. Organizations dealing with both must comply with both regimes. Key Differences: Supervisory Authority: EU = multiple DPAs; UK = ICO. International Transfers: UK maintains its own adequacy decisions. Representatives: Non-UK organizations must appoint a UK representative if targeting UK residents. Enforcement & Fines: ICO enforces UK GDPR; penalties mirror EU but are applied separately. Practical Steps: Maintain separate Records of Processing Activities (RoPA) for UK and EU. Update Privacy Notices to mention both legal bases. Monitor divergence — new Data Protection Bill may introduce more changes. Useful Links: ICO UK GDPR Overview EU GDPR Portal
