Inspired by Gavin Freeguard’s National Data Strategy Sea-Shanty, and in homage to the shanty-makers (I’ve worked the North Atlantic on small ships), here’s my “Adequacy Shanty”…
Farewell and adieu to you, fair Spanish data,
Farewell and adieu to you data of Spain,
For our UK law may be judg-ed inadequate,
And we may never see your fine data again.
The first of our problems is data retention
Ruled non-compliant in twenty sixteen;
Then a new issue with immigration processing
Oh how can we fathom just what that might mean?
Farewell and adieu…
We’ll rant and we’ll roar about model clauses
Or, where it’s appropriate, write BCRs.
For contracts essential and users consenting
We have to be grateful to our lucky stars
Farewell and adieu…
Perhaps the Commission will rule in our favour,
And judge our position with some sympathy?
A problem postponed, or a permanent solution?
We wait for the outcome of Schrems number three!
Farewell and adieu…
