Mr. John O'Dwyer:

We had been preparing quite substantially up to the end of the year on the basis that, if there was not an agreement, this would all happen from 1 January. Ms Coogan and her team had been engaging in a large way with business representatives, SMEs, IBEC and other such organisations. We had also been feeding into the Government's Brexit strategy through making information available on our website and Government websites to ensure that businesses were aware of the implications for them and what they had to do. We have provided a great deal of information on this already but if it looks like there will not be an adequacy decision in place by the end of June, we will restart that process of ensuring businesses are aware of their obligations and what they need to be doing. We get the impression that it is a mixed bag. The big organisations have plenty of resources and can put money into this and employ experts to do it. The biggest problem with much of this, and with Brexit in general, is trying to help the SMEs, particularly if they are not people who deal in data, as they might send to the UK or Northern Ireland for HR or payroll services.

We have met companies in the Border region that say they have been dealing with UK companies in the North for the last 20 years for their payroll and that those companies are only up the road. We say that up the road is still across the Border and that they need to take that into account. They say they have always dealt with those companies, that there has been no problem and that it is just up the road. We are saying to them that if there is no adequacy decision, up the road is across the Border and dealing with those companies will be an international transfer to a third country, with all that goes with that. They need to put the various safeguards, whether standard contractual causes or other mechanisms, in place. A standard contractual clause is probably one of the most obvious mechanisms for most companies. There are serious issues for companies to consider. These are things that they do not normally think of because they do not think they deal in personal data.

When people talk about data transfer, they automatically think of the Facebooks, Googles and Twitters of this world but it is happening in thousands of companies every day of the week.