Columnist Camilla Ravazzolo Data protection boundaries know no EU border R umour has it, you can take the girl out of the country but not the country out of the girl. The UK might well have left the European Union but it hasnt broken all ties just yet. Whether you are a 48 or a 52, it doesnt really matter when it comes to data protection: its principles, values and ethics are here to stay. That doesnt mean they are dogma, or not up for discussion. Au contraire! Only one thing is more exciting than a pure doctrinal discussion about rights and freedoms: a practical one. How are businesses impacted? What does it mean for small and micro companies? Can I guarantee the safety of my research participants from existential threats? This is why conversations are important. This is why, when guidelines and guidance are drafted, their aim is not governing the laws of the universe but rather easing everyday life applications. MRS has always championed conversations, especially with members, but also with other national, European and international associations. One in particular is always close to its heart: Efamro. It is the European research federation, representing the interests of market, social and opinion research in Europe. Its members are national trade associations for research businesses. Its playground is Brussels and the European institutions. Its role is to promote the interests and needs of the sector, make sure that voices are heard, and pleas accepted. And lately, it has been very active. First things first, a check-up on the GDPR. In April, Efamro published and submitted the position paper A Response to the ECs Roadmap Report on the General Data Protection Regulation. In association with the European Pharmaceutical Market Research Association (EphMRA) and the British Healthcare Business Intelligence Association (BHBIA), Efamro asked the European Commission to: Review and update standard contractual clauses and adopt new EU processor to non-EU or EEA processor clauses. With only 56 13 adequacy decisions in place, businesses need to refer to other tools listed in Chapter V. Standard contractual clauses for data transfers to third countries have not been updated since they were originally adopted. The commission should urgently review and revise the standard contractual clauses and consider the needs of controllers and processors with the addition of new clauses to cover EU processor to non-EU or EEA processor data transfers. Clarify and publish additional guidance on codes of conduct. The different sectorial experiences in devising sector codes has demonstrated that there is some degree of uncertainty regarding codes of conduct by sectors and the same data protection authorities that should be in charge of adopting them. Investigate further and get a better understanding of how the issue of overlapping territorial scopes of national laws implementing the GDPR has affected controllers and processors, and how they are dealing with such fragmentation. The GDPR is directly applicable in all member states but it also leaves a margin for national legislators to maintain or introduce more specific provisions to adapt the application of certain rules. This national margin has resulted in a fragmented legal landscape for some of the GDPR provisions. In turn, the non-uniform application of the GDPR across member states can create obstacles to cross-border operations, even intra-EU. Highlight the broad need for practical guidelines. On the one hand, businesses may accept the best analysis that fits their interests and consequently adopt practices that would fall in a grey area at best. On the other hand, by focusing relentlessly on the methods and impacts of technology giants, the realities of micro, small and medium-sized enterprises are being overlooked, as are those sectors, such as research, which follow existing rigorous codes supporting ethical personal data practice. Among many, one topic in particular is still very much up for debate. For Efamro members, the most interesting example of national fragmentation is the concept of scientific research, which