|By Christopher Harrold||
|August 6, 2016 12:00 PM EDT||
Yes this post is about the #Brexit, but it's about your data more importantly!
As a company that has a large customer and open source user community in the EU, I thought a quick note on some considerations following the Brexit vote were in order. This is not an opinion piece, as that would seem to be casting stones at this point. The vote is done and the process will move forward as it was voted, but I do think the impacts of this decision are going to be incredibly disruptive and likely felt for a long time to come in many ways well outside the economic or political realms. There is no sector of industry or field of study that will not face potential disruption, and the deeper and larger ramifications of the departure of the Kingdom from the EU are starting to come into focus. If you think there isn't impact for data analytics, think again!
Data in Europe, and personal and "habit" data in particular (think purchasing history online, or tracking activity on social media), is something that has far more significant importance, and is treated with far more value and discretion than is the case in the US. A concept of universal sovereignty of data has been in place in the EU for a while now, and it is something that most EU companies have both benefited from and understood innately as a requirement for the care and custodianship of data. This has led to sometimes complex and very fine-grained approaches to protecting data and ensuring it is not transmitted across specific borders.
Many organizations in, or who do business in the EU sphere, are already governed by these data sovereignty laws, and the complex business lexicon required to manage and integrate data without violating sovereignty is extensive and can be very painful to rework. Significant investments in infrastructure, tooling, and overall application development and design could be needed in order to address the emergence of Britain as a fully separate entity from the EU. This could include:
- Physically moving data into or out of Britain (this is NOT trivial - cloud providers especially need to think about this as they are, by design, "borderless"
- New business rules to track and mark data as originating in or terminating in a newly separated Britain
- Potential impacts on import controls and the changes in restrictions for what can and cannot be brought in or out of Britain to the EU and beyond
- Assuming that Britain retains common EU market access with the stipulation of free movement for EU citizens, there may not be a need for personnel considerations, but this is far from decided and there could be serious impact for non-EU residents of Britain
- The EU, while generally respecting member-state's data "borders," did have provisions to allow some data to free-flow from place to place inside systems. With the departure of Britain, this data border will suddenly become much more "closed" meaning that it is very likely there will be major new rules in effect regarding sovereignty of data. For example, it will likely be difficult if not impossible to aggregate data for the EU in Britain and vice-versa because they are no longer "the same" in terms of that data sovereignty.
- Britain now has a chance to develop its own privacy and data sovereignty law outside of the EU norm. This could mean (but unlikely) a dramatic increase or decrease in what types of data can be collected and analyzed. As I said before, the EU is already very strict about "opt-in" collection of personal data, and the British exit is highly unlikely to change that for Britons, but it is worth watching in case there is substantial change.
- If you have data from multiple countries, data aggregation may become more difficult with respect to British vs EU data. Also analytics models, business rules, ETL rules, and overall processing information is likely to need adjustment to reflect the new "lay of the land" in the European sphere.
- Also worth keeping an eye on is the potential "secondary referendums" that could be triggered with respect to Scotland and Norther Ireland who voted to stay in the EU. If they enact additional sovereignty measures, it could become even trickier to navigate the data laws for the area if new sovereignty emerges.
With the British exit logistics being worked out, albeit not immediately, as the actual process could take many months or even years to enact, the data sovereignty impacts will almost definitely change. Key impacts to consider for your organization's data:
Overall the immediate impact of the Brexit vote for your data is not likely to be felt for at least a few weeks or months as the actual process for EU separation is figured out, but it is very important to begin an internal catalog of your data; its movement and its location and sources, in order to stay ahead of the turmoil that could result from changes in the data sovereignty situation. Whether you were against or supportive of the Brexit movement, the choice has been made and now it is critical to begin preparing and finding solutions for the disruption before its impacts are too great.
Want some guidance or additional information about how you can harden yourself to protect against this change? Let's talk; I can help you identify material gaps in your stewardship plans, prepare for the transition to an EU without Britain, and make sure that you aren't caught without a transition plan for your critical business data.
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