According to a report in the Financial Times, US tech giant Dell, hotel chain Hyatt, telecoms group BT, and Royal Bank of Scotland have already started investigating alternative arrangements, with Ireland and the Netherlands emerging as front-runners for companies setting up data hubs outside the UK.
Achieving an adequacy agreement is far from easy. After years of negotiations, Japan recently joined the exclusive club of 11 relative minnows, including Argentina, Israel, and New Zealand, which are considered to have the same level of personal privacy protections as Europe.
In its recent Brexit White Paper, the UK Government demanded guarantees that British companies – which operate in a digital economy worth around £240bn – will not find themselves suddenly cut off from Europe.
However, so far Brussels has refused to play ball, with EU chief negotiator Michel Barnier also rejecting calls for Information Commissioner Elizabeth Denham to retain her place on the new European Data Protection Board.
A UK government spokesperson told the FT that the UK would “continue to make the case for an ambitious future EU-UK relationship on data protection”
And EU justice commissioner Vera Jourova has offered a glimmer of hope by saying there were “positive signs” an agreement will be reached once the UK makes a formal request for an adequacy deal. “We definitely will want, for the sake of business interests the quickest and most efficient legal framework for the exchange of data with the UK,” she said.
However, she added that Brussels would be looking for assurances that the UK would not weaken its privacy rules after Brexit.