No transition period has been granted by the supervisory authority in Luxembourg (CNPD). In the face of the twists and turns surrounding BREXIT, it is better not to remain inactive but rather to sign standard contractual clauses with your partners today. If your group of companies is concerned, you might want to think of establishing an intra-group agreement and appointing a representative, subject to conditions precedent, if appropriate. Such an agreement would also allow you to effectively resolve issues related to Article 28 (processor and sub-processor).
Our Digital team is at your disposal to assist you with your compliance as well as in responding to concerned persons and supervisory bodies.