GDPR across Borders – Ireland, Northern Ireland, The UK & Data

In 2025, General Data Protection Regulation (GDPR) remains a cornerstone of data protection law in the European Union. Cross-border businesses face unique challenges in achieving compliance due to variations in data handling practices and differing interpretations of the law across jurisdictions. This eBook is your step-by-step guide to navigating GDPR compliance as a cross-border business, complete with actionable checklists to ensure your organization meets the highest standards of data privacy.

Understanding GDPR Basics

The General Data Protection Regulation (GDPR) is a comprehensive data protection law enacted by the European Union. It came into effect in 2018 and aims to protect the personal data of individuals within the EU. GDPR applies to any organization, regardless of location, that processes personal data of EU residents. There are 7 fundamental principles that you can use to process the subject’s personal information:

Lawfulness, fairness, and transparency: Personal data must be processed transparently and lawfully.
Purpose limitation: Data should only be collected for specified, legitimate purposes.
Data minimization: Only collect data necessary for the intended purpose.
Accuracy: Ensure personal data is accurate and up to date.
Storage limitation: Retain data for no longer than necessary.
Integrity and confidentiality: Secure data against unauthorized access and breaches.
Accountability: Being able to demonstrate GDPR within your organisation.

Within your company there are a few key steps you can undertake to ensure the smooth handling of GDPR and Data and these would be my top recommendations for a great place to start if in 2025 you really want to get ahead and get a good handle on your journey to GDPR compliance.

Appoint a Data Protection Officer (DPO): If your business processes large amounts of personal data or handles sensitive data, appoint a qualified DPO. This can be someone within your business who undergoes training or it can be someone external you hire in.

Train Employees: Conduct regular training sessions on GDPR principles and best practices for handling personal data. Even with an appointed DPO every staff member should understand GDPR and know what their responsibilities for Data are.

Document Processing Activities: Use tools or templates to maintain a Record Of Processing Activities (ROPA). A RoPA, as well as being a compliance and risk management tool, will assist a data controller in identifying personal data processing that may not be necessary, and may help in demonstrating to data subjects a commitment to best practice data protection policies and procedures.

Update Privacy Policies: Regularly review privacy policies to ensure they align with current GDPR requirements and reflect actual practices. If you haven’t looked at your privacy policies in a while this is possibly the most important thing you can do in 2025. Without an adequate and updated privacy policy you could be leaving yourself open to issues.

Also consider if you should have an external policy that will sit on your website and also an internal one for staff and processes.

Establish a Data Protection Policy: Create and disseminate an internal policy detailing GDPR compliance processes.

Data Mapping for Cross-Border Businesses

Data mapping involves identifying what personal data your business collects, where it is stored, and how it flows across borders for example if you have data that is shared on a spreadsheet that is accessible from the UK office and the ROI office.

This is essential for:

Identifying compliance gaps.
Streamlining response to data subject access requests (DSARs).
Ensuring proper data transfer mechanisms are in place.

How to carry out a Data Mapping Exercise in your Business

Identify Data Sources: Compile a list of all data sources, including internal systems, third-party vendors, and customer interactions.
Create a Data Inventory: Document all personal data types collected, storage locations, and retention periods.
Map Data Flows: Visualize data flows to understand how data moves across systems and borders.
Verify Legal Basis: Confirm the lawful basis for processing each category of data, such as consent, contract necessity, or legal obligation (refer back to the GDPR Principles above).
Review Data Access Controls: Ensure only authorized personnel can access sensitive data.

Cross-Border Data Transfers

Cross-border data transfers are a critical compliance area under GDPR. Later in 2025 the UK Adequacy decision is expiring so any changes in this area need to be addressed in your documentation. Currently the UK operates UK GDPR which is still very much aligned with the EU GDPR but over time this will probably change and this is an area that needs to be monitored closely. Given this difference the following areas are of interest:

Standard Contractual Clauses (SCCs): Updated in light of Schrems II and further court cases that are pending.
Binding Corporate Rules (BCRs): Internal rules for multinational companies.
Adequacy Decisions: When transferring data to countries deemed adequate by the EU.

Consent Management

GDPR sets a high bar for consent and this is one of the most important factors for GDPR in any business – it is also where I come across lots of problems with understanding consent as it can also impact marketing, emails and newsletters.

It is always worth remembering when collecting data that consent must be:

Be freely given, specific, informed, and unambiguous.
Businesses must provide individuals with the ability to withdraw consent easily.

Checklist: Consent Management

When you are collecting data this is a great checklist to refer to and to keep coming back to ensuring your processes remain compliant.

Design GDPR-Compliant Forms: Create consent forms that clearly explain what data is collected and why.
Implement Withdrawal Mechanisms: Include options in emails, websites, or apps for users to revoke consent i.e. unsubscribe etc.
Maintain Consent Records: Use a consent management platform to log when and how consent was given.
Refresh Consents Periodically: Revalidate consents for long-term data processing to ensure ongoing compliance.
Avoid Bundling Consents: Ensure that consent requests are separate from other terms and conditions.

Handling Data Subject Rights

Always remember that the subject (this might be a follower of your business on social media right up to one of your top level employees) have certain key rights under GDPR:

1. Right to access: Individuals can request copies of their data.
2. Right to rectification: Incorrect data must be corrected.
3. Right to erasure: Individuals can request their data be deleted.
4. Right to data portability: Allows for data transfer between providers.

Right to restrict processing: Individuals can ask you to stop processing their data

Right to object: Individuals can object as to how you are processing their data.

Right not to be subject to automated decision making: ie insurance quotes based on algorithms or pre-determined data.

Managing Data & Subject Rights

Within your company there are basics that must be covered to ensure that you are managing the rights of the subject – again this is something that becomes trickier when managing the processing and flow of data from within and outside of the EU as everyone has different rules. If you are unsure at any time, remember you can get advice from a GDPR professional, the DPC within Ireland and the ICO within the UK.

Actionable steps to take :

Establish a specific GDPR email address: Create an r email address for data subject requests.
Develop Response Protocols: Define steps for verifying identity and responding to requests within 30 days.
Automate Request Handling: Use software to track and manage DSARs efficiently.
Create FAQs for Customers: Provide clear instructions on how individuals can exercise their rights.
Log All Requests: Maintain records of all data subject requests and your responses to them.

Third-Party Vendors/Suppliers and Processors

Managing Vendor/Supplier Relationships is very important and even more so when you are dealing with data in different countries. GDPR holds businesses accountable for the actions of their data processors. Ensure that all third-party vendors adhere to GDPR requirements.

To ensure Vendor/Supplier Compliance you should look at carrying out the following;

Audit Vendor/Supplier Agreements: Ensure all contracts include GDPR-compliant data processing terms.
Vet New Vendors/Suppliers: Assess new vendors’ data protection measures before onboarding.
Schedule Regular Audits: Periodically review vendor compliance with GDPR obligations.
Maintain a Vendor/Supplier Register: Keep a detailed list of all vendors and their roles in data processing.
Define Breach Protocols: Ensure vendors understand their responsibilities in case of a data breach.

Ongoing Compliance and Monitoring

Compliance is an ongoing effort, not a one-time task. Regularly review and update your practices to align with evolving regulations and business needs and be aware that in the second half of 2025 rules and regulations will be changing and coming into place surrounding the UK adequacy decision. You must be ready to demonstrate your compliance.

Conduct Annual Audits: Perform yearly GDPR compliance reviews.
Monitor Regulatory Updates: Stay informed about changes to GDPR and related laws.
Create Internal Compliance Reports: Regularly report on compliance metrics to leadership.
Use Compliance Tools: Leverage automation tools to monitor data processing activities.
Promote a Culture of Data Protection: Regularly reinforce the importance of data privacy within your organization.

Achieving GDPR compliance as a cross-border business in 2025 requires proactive efforts and continuous vigilance. By following the checklists and recommendations in this guide, you can ensure your business not only meets its legal obligations but also builds trust with customers and partners through responsible data practices.

If you would like to book a call to talk about how I can help your company with your GDPR responsibility you can do so here