Virtustream, a Dell Technologies business, has prepared for the transition of the UK out of the European Union (EU) to achieve business continuity and minimal disruption, working jointly with customers, partner and suppliers pursuant the EU-UK Trade and Cooperation Agreement reached on 24 December 2020.
As part of Dell EMC’s internal efforts to prepare for Brexit, a Task Force was established to look at the main impacts of Brexit on Virtustream and its relationships with its customers, vendors and partners. Its role is to ensure that relevant operations, such as cloud services and data security, are conducted in accordance with the EU-UK Trade and Cooperation Agreement . Dell EMC also appointed an Executive Steering Committee to guide and assess the work undertaken by the Virtustream Task Force.
Virtustream’s Trust Office and Product Management functions have been working to mitigate risk pursuant the achieved EU-UK Trade and Cooperation Agreement. The workstream is taking into consideration legal, trade, compliance, regulation and tax aspects.
Virtustream geographical locations in Europe include the UK, Germany, France, and the Netherlands. Brexit planning has been ongoing with suppliers to ensure the availability of data movement between primary and secondary data centers that may be impacted by Brexit.
Data security and incident management requires an organization to have appropriate technical and organizational security controls and procedures in place to secure data subjects’ personal data that they are processing as well as notify the affected data subjects and/or an EU supervisory authority in the event of a data breach that is likely to result in a high risk to the rights and freedoms of data subjects. Virtustream’s data security and incident management procedures will be reviewed and aligned with the applicable UK regime in accordance with the EU-UK Trade and Cooperation Agreement to ensure proper measures are followed.
Accountability principle essentially means an organization must demonstrate that they comply with the GDPR data protection principles. Virtustream’s achievement of the CISPE Code of Conduct validates our commitment to GDPR compliance in our Enterprise Cloud.
Virtustream will continue to evaluate appropriate codes of conduct, applicable under the UK Regime.
Virtustream provides its customers with various data center choices to accommodate GDPR transfer restrictions. Virtustream does not transfer its customers’ data without consent.
The EU-UK Trade and Cooperation Agreement provides that, for a maximum period of six months from its entry into force until 30 June 2021 at the latest, all data flows of personal data between stakeholders subject to GDPR and UK organisations will not be considered as transfers to a third country. Therefore, at this stage, there are no required changes to Virtustream’s international transfers adequacy process as all legal data transfer requirements are met.
On 19 February 2021, the Commission launched the procedure for the adoption of two adequacy decisions for transfers of personal data to the United Kingdom, under the General Data Protection Regulation (GDPR) and the Law Enforcement Directive (LED) respectively
Virtustream’s parent company Dell EMC urges both the UK and EU governments to agree an adequacy agreement on data protection to ensure the continued smooth data transfer post Brexit. To the extent that an adequacy decision for the UK is not approved by the European Commission until 30 June 2021, transfers of data between the EU and the UK would be considered international transfers. In the absence of an adequacy decision by the European Commission in relation to the UK, Virtustream encourages its customers to review its data center choice and data protection schedule to ensure that it has the necessary safeguards with respect to its data, including the Standard Contractual Clauses if applicable.
Our business performance or ability to service our customers is not reliant on free or unhindered movement of staff within and across EU member states. The vast majority of Virtustream employees in the UK are skilled professionals currently drawn from the UK and Ireland which will be unaffected by Brexit as the free movement of labour within these two countries pre-dates the European Union. Virtustream will continue to support team members through this period of uncertainty and seek to secure the necessary visa or permits in order for team members from EU member states to continue working in the UK.
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