The General Data Protection Regulation (“GDPR”) and the new Data Protection Act 2018 (“DPA”) now apply in the UK. SaaS suppliers and SaaS customers must comply with the terms of both the GDPR and the DPA. SaaS suppliers and SaaS customers should be aware that the GDPR does not fully harmonise data protection law throughout Europe, as each EU country may introduce their own requirements in certain instances (“derogations”). SaaS suppliers and SaaS customers who operate in, or collect or process personal data from persons located in different EU countries need to be aware of the different rules in each EU country.
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