FAQs: dotdigital & Brexit

Note that this note is provided for informational purposes only. For more information on the consequences for you, please see the Government’s Brexit advice pages or seek your own legal advice.

For any specific queries relating to Brexit and dotdigital’s preparations, please contact [email protected].

1. What is dotdigital doing to prepare for Brexit?

dotdigital has a team established with key stakeholders across the business (both internal and clientfacing) to implement contingency planning.

2. Will Brexit impact the provision of services?

We do not anticipate that Brexit will have an adverse impact on the supply of services to our clients. There are no staffing implications from Brexit. The one key element critical to our provision of services to clients is with regard to client data – we are taking steps to address these concerns as we have outlined in this FAQ.

3. Which dotdigital clients will this affect?

Brexit will affect any dotdigital clients that are located within the EEA or uploads data about individuals located within the EEA.

4. Where does dotdigital store data?

The dotdigital CPaaS platform is hosted in Microsoft Azure and Google data centres. Data for our European clients is held in the North Europe region (Ireland). A map showing the Azure date centre locations can be found here.

5. Why will dotdigital transfer data to the UK?

dotdigital uses data centres located within the EU as outlined above, however dotdigital is primarily a UK-based business. UK-based staff will need to access this data for the purposes of providing our core services, as well as providing support and professional services.

6. How will dotdigital continue to transfer data from the EU to the UK in the event of ‘no deal’?

In the event that the UK leaves the EU without a deal, the UK will be considered a ‘third-country’ for the purposes of the GDPR. As the UK will have no adequacy decision in place transfers from the EEA to the UK will have to be done in line with appropriate safeguards outlined in Article 46 of the GDPR.

As a group, we ensure that we have adequate safeguards in place across our organisation and global entities. We have an intra-group agreement incorporating the EU Model Contract Clauses and ensure that the EU Model Contract Clauses are in place with our sub-processors.

7. How will this impact clients?

To ensure the ongoing provision of services comply with European data protection legislation, we are urging our clients to enter into Model Contract Clauses with dotdigital.

If you are based in Europe, we will be reaching out to you with a copy of these for signature. If you wish to request EU Model Contract Clauses with dotdigital, please email [email protected].