UK GDPR Representative Service

Our administrative costs of processing an online purchase are much lower than for an offline purchase and we pass those savings on to you.

The UK representative’s role is to ensure that individuals (data subjects) and the UK’s data protection authority, the Information Commissioner’s Office (ICO) have a mechanism which allows them to communicate with organisations. A key driver behind this is to make sure that UK residents will be able to contact the data processors and controllers who hold their personal data in a quick, efficient and simple way.

Put simply, under Article 27 of the UK GDPR if your organisation has no business presence in the UK you need to appoint an UK representative if:

• You offer goods or services to individuals in the UK; or
• Monitor the behaviour of individuals in the UK. 

Monitoring or “profiling” within the GDPR framework means anything you do that involves the automated analysis or predicting of behaviour of individuals, their movements, personal preferences, health, economic situation etc.

There are limited exceptions to this, depending on the volume and type of data you are processing or whether you are a public body or authority. However, the extent to which exceptions apply has not yet been tested.

Since the 1st January 2021 the UK is no longer a member state of the European Union so organisations that don’t have a business presence in the UK but are marketing to the UK or monitoring the behaviour of people in the UK now need a UK representative. In some cases you may also need to appoint an EU representative. For example if your organisation is based outside Europe and the UK and your EU representative was previously based in the UK.

As details of the UK representative need to be easily accessible, typically in your privacy documentation, - for example your customer facing privacy notice or published on your website - it is obvious if you have failed to meet your Article 27 obligations. If you are in breach of Article 27 you may face fines of up to ten million Euros or 2% of your global turnover.

We act as a communications conduit between data subjects and your organisation and the ICO, provide you with a UK representative email address, wording to insert into your privacy notice (s) and hold an up to date copy of your Article 30 record of processing activities, as required by Article 27. We pass any enquiries from data subjects or the ICO to you to deal with.

This is an annual fixed fee service. Our pricing is based on the size of the organisation and we charge per entity.

We can provide a UK representative for all group entities, but we charge based on the number of entities that need to be included.

No, we charge a flat fixed fee based on the size of your organisation.

It is not required under the regulation but you need to make details of your UK representative easily accessible, for example in your privacy notice or by publishing details on your website.

The Article 30 record is a key document for GDPR compliance and should document what data you are processing and why, where data is stored, the volume of data you are dealing with and how it is moving through your organisation. If don’t have an accurate picture then you may not be aware of where your compliance gaps are and where you might be in breach of the GDPR. You also need to have one readily available in case a data protection authority asks to see it.

The exemptions are very limited and haven’t been fully tested. Without an accurate and up to date record of processing activities it is difficult to be assured that you are compliant. It is best practice to have one and we strongly recommend all clients have one and keep it up to date.

The GRCI Law team can help you with this but it is not included in this service. We would be happy to talk to you about your specific requirements.

Ideally, as soon as you sign up or as soon as possible.

We pass all enquiries from data subjects to you to deal with along with any enquiries from data protection authorities.

We would contact you first before responding to a request from the ICO.