Mr. John O'Dwyer:

There is quite of lot to address there and I will try to cover as much as I can. I will ask Ms Coogan to cover the issue about cross-border transfers between the same entity.

We will have to wait to see how vaccine certification pans out, what exactly will be involved in respect of personal data and how that data will be transferred. A data protection impact assessment may have to be carried out on any data that would be processed as part of the certification and the underlying legislation that would be put in place. Would it be national legislation or EU legislation? There is much to play for yet before we can give an opinion on exactly what data protection issues arise. Anyway, we are available to be consulted. Like any legislation or new project, we are available to give our views on it.

Senator Byrne raised an issue about surveillance and divergence. Obviously, this would be a major issue. One of the issues in the Court of Justice of the European Union ruling was the concern in the USA about mass collection of data. If that were to start happening in the UK there would be major concerns. This is all yet to be seen. The same issues would arise as arose with the US in respect of surveillance if that was to happen. I will ask Ms Coogan to give more detail on the transfer of data from the same entity across a border.