Virtustream BREXIT Statement

Virtustream, a Dell Technologies business, has been preparing 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.

As the EU and UK discussions and negotiations continue beyond the originally anticipated exit date (October 31, 2019), Virtustream continues its BREXIT preparedness activities, conducting ongoing strategic impact assessments and taking proactive measures to mitigate the potential impacts on Virtustream’s business in different potential Brexit scenarios.

Through this period of uncertainty our focus remains committed to offer the world class cloud for mission critical workloads to our customers and partners.

Brexit Task Force & Steering Committee

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 preparing for different Brexit scenarios, including ‘Hard’ or ‘No Deal’. Dell EMC also appointed an Executive Steering Committee to guide and assess the work undertaken by the Virtustream Task Force.

Virtustream Enterprise Cloud Products and Services

Virtustream's Trust Office and Product Management functions have been working to mitigate risk should the UK government not secure frictionless movement of goods, services and data. The workstream is taking into consideration legal, trade, compliance, regulation and tax aspects. 

Virtustream geographical locations in the European Economic Area 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

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 evaluated based on the potential outcome of Brexit to ensure proper measures are followed. 

Accountability Principle

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 applicable codes of conduct based on the impact and outcome of Brexit.

Data Storage and Transfer

Virtustream provides its customers with various data center choices to accommodate GDPR transfer restrictions. Virtustream does not transfer its customers’ data without consent.  

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. In the case of a no-deal Brexit, however, 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.

HR and People                            

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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