Brexit, Covid, Data, and Change

As noted last week, the plethora of vaccines suddenly emerging to take the field of the pre-approval Covid solutions stakes offer a ray of light at the end of the pandemic tunnel. But, just as we breath a small sigh of reliefe Brexit change is coming.While we are still dealing with this pandemic.

However the challenge of vaccinating a population will still allow most governments the opportunity to continue to behave incompetently.  In Peoples’ Republic of Ulster we are blessed with a political class who sometimes appear excel at multitasking. They can appear both incompetent and intransigent at the same time.  As proof of the readiness to run a vaccination programme a couple of hundred thousand flu jabs were lost and then found, much to embarrassment of all at Public Health NI.   Of course these are all basic data management and literacy problems.

And where politics is concerned classification or definitions are important.  So, not enough vaccine was ordered.  Of course not, as orders would be based on previous uptake and target populations in a forecast based on previous models.   More have been ordered and are awaiting delivery.   How you classify that can be open to interpretation.  The inability to see across the national/devolved/supply chain makes it all very tricky, but that’s simply because there is no overall data strategy informing the data supply chain.

What changes does Brexit bring?

These governmental problems are reflected in society by organisations unpreparedness for the other upcoming but easily foreseen change.  As I write the EU and the UK continue to negotiate or at least dance around the challenges of both building unrealistic expectations in their constituencies and decide whether or not a deal will be forthcoming.  The collective breath of business across these islands is held over the possibility of a trade deal for goods, and the level of tariffs on grass guzzling gas emitters, while for the most part ignoring the fact that the Withdrawal Agreement has pretty much set the framework for our future relationship. And the Brexit Change will be significant.

The first unintended consequence of what will become known as the “Ulster paradox”. The small province that’s too small to move the economic dial. The small province that, like a religious mystery, is both in and out of two different unions. How long before the realisation by Scots fishermen that re-registration of the boat to an Ulster port may be economically advantageous?   But fear ye not, faced with the opportunity to benefit from the transfer of jobs, and to economically develop coastal towns Ulster will follow the traditional route of saying no.

We don’t like change up North! Brexit Change will be no different.

Of course, here at the coal face of data governance and data protection, leaving the EU is already driving change, although too few people seem to know this.  From January any organisation holding UK data in the EU or EU data in the UK will suddenly have a new data risk in the organisation and new obligations to 2 different regulatory regimes.  There may be a need for a Nominated Representative in the other jurisdiction, to support the home country DPO.

There is significant potential for the UK to join the USA on the list of countries that will not guarantee the rights of EU citizens. Therefore transfers will require more care and documentation.  Documentation is the manifestation of the friction in the trade system that Brexit is guaranteed to generate as the UK moves away from the EU.  Its good to see that the UK has today announced that GCHQ is kindly helping HMG with the Covid app data, an involvement forecast here back in March. however, it is unlikely to contribute positively to an equivalence agreement for data protection and this is of course one of the key underpinnings upon which financial services equivalence (amongst other things) will rely.

Change is Constantly Coming

While we may not like it here, Brexit change is coming. And change has already landed with Covid.  The move to Connected Working is becoming unstoppable.  Irish government is already being criticised for the delay in proposals to enshrine a right to connected working, and to shift the financial burden for connectivity from the resident to the employer.

If it is unethical for employers to piggy-back on the employees personal wifi, how much more so is it to expect employees to pay PAYE, PRSI, and USC prior to payment of the business expense and VAT after! From an employer’s perspective how can you protect internal data over infrastructure you have no right to control.  The whole field of connected work, like all change, brings unanticipated changes, but by this stage in the process we can see that things won’t go back to the way they were,  and that new solutions are required.  I wonder how many suddenly connected organisations could produce the documentation and controls to mitigate the new risks that have been accepted over the last 8 months.

Change is here and more is to be expected.  2021 is going to be a tough year across the British Isles in both business and politics.  Those that do best will be those who have foreseen the changes already on the horizon and made adequate preparations to mitigate.  Whatever happens with the pandemic, the structural changes driven by new trade arrangements need to be met and overcome, and the move to connected working will not turn around.

Getting Ready for Brexit Change

Castlebridge can help organisations of all sizes get ready for Brexit. It’s not too late to start!

From Nominated Representative Services for EU to UK and UK to EU to full analysis of business data strategy to help navigate disruption, we can provide insight, analysis, and support to help get you pointed in the right direction.

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