Transition Period
During the transition period (also known as the implementation period), businesses would face ‘business-as-usual’ arrangements for the handling and protection of data. The EU will provide an assessment of the UK’s data protection standards through its ‘adequacy framework’ (which underpins business, governmental and security partnerships) by the end of 2020), with comparable activities in the other direction from the UK. There is a commitment to cooperation between regulators.
Backstop
In the event of a backstop arrangement coming into force, UK domestic rules on data protection will apply. The Political Declaration and Withdrawal Agreement contain no information on mobile roaming in this scenario.
Post Transition / Backstop
Post- transition or backstop, UK domestic rules on personal data protection will apply. The EU and the UK hope to have in place relevant frameworks to support data protection standards by the end of the transition period, providing that the correct standards are met.
The UK leaving the EU would not prevent UK mobile operators making and honoring commercial arrangements with mobile operators in the EU – and beyond the EU – to deliver the services, including roaming arrangements. The availability and pricing of mobile roaming in the EU would be a commercial question for the mobile operators.