
Google users in UK to lose EU data protection – sources - vinnyglennon
https://www.reuters.com/article/us-google-privacy-eu-exclusive-idUSKBN20D2M3
======
thinkingemote
The UK has all the EU laws it had before Brexit. It needs a new law in the UK
to remove existing things. UK will not lose protection until the UK decides
upon it.

~~~
TheRealPomax
Except not quite: while the UK will have laws that effectively mirror the
GDPR, the crucial difference is that it's now a UK law, not a European law,
and there is no EU enforcement of that UK law.

UK citizens also won't be able to appeal all the way up the EU courts: it
stops at the UK supreme court.

And most importantly: now that the UK is out of the EU, it is a tiny, barely
relevant factor in multinational corporate online practice. Any business that
gets told by the UK to follow their GDPR can quite comfortably go "lol, no"
and barely affect their bottom line, as opposed to having the entire EU block
go "obey our GDPR or we won't let you do business in any of these 27 nations,
a large portion of which make up a substantial cut of your global revenue".

The biggest players won't, of course, but smaller companies?

~~~
mattmanser
The 3rd biggest online market is barely a blip? And probably the 2nd biggest
for the US because of the shared language.

Poorly informed comments like this pop up a lot, they don't understand the
reality of just how big the UK economy is compared to the vast majority of
coutnries that make up the EU.

The UK was 20% of the EU's GDP, 1/5th of the total GDP out of 27 countries.

~~~
ben_w
The EU+UK combined is about the same size as the USA. _No_ EU country alone is
a world player any more, that’s basically the entire reason everyone got
together to negotiate trade issues as a block.

I agree with you that the language barrier is stop going to be at least
somewhat important.

~~~
squiggleblaz
I guess it depends on your definition of a "world player". By GDP, it goes
something like US, EU, China, Japan, India, UK, Brazil, Canada, Russia, South
Korea, Australia. There's a fairly large gap (more than double) between Japan
and China.

Obviously exact orders will depend on the estimate and how fair it is to use
2019 figures and then subtract the UK from them.

But however you slice it, the UK is not pocket change. Maybe smaller companies
can ignore all but the largest three, but I doubt it.

It's more likely that the UK will prefer a more liberal market, and for that
reason their laws will be a little ignored - they won't enforce them and will
forever be planning their repeal even if they never quite get there.

~~~
stoobs
GDP rankings are as follows from the last posted results (2018):

    
    
      1) United States 20,544,343.46
      2) China 13,608,151.86
      3) Japan 4,971,323.08
      4) Germany 3,947,620.16
      5) United Kingdom 2,855,296.73
      6) France 2,777,535.24
      7) India 2,718,732.23
      8) Italy 2,083,864.26
      9) Brazil 1,868,626.09
      10) Canada 1,713,341.70
    

So out of "EU" it's only Germany which was larger according to those figures
(from the World Bank).

Of course things will have changed over the last couple of years, but I doubt
it is substantially different in terms of order.

~~~
mattmanser
UK's been ping-ponging between 5th and 7th due to the pound fluctuations.

In reality the EU is not a unified market for e-commerce because of the
language barriers and very large discrepancies in laws. For example, France
has some pretty crazy stuff to protect the French language, Germany is very
strict about certain subjects and the denial of them like the holocaust. And
while there are some top level EU laws or efforts to police the bigger
internet players, enforcement is still mainly regional too.

I'm under no pretensions that the UK is far, far from the super-power status
of the US or now China, or previously USSR.

But if we're a blip, most countries in the world aren't even a notch.

~~~
ben_w
> But if we're a blip, most countries in the world aren't even a notch.

That is the impression I’ve been getting from what economists have been
saying. Of course, not being in economist myself, there is no way for me to
tell if I’m reading _real_ economists or merely people wearing economist
clothing.

------
YetAnotherNick
What exactly are the EU protections that I don't get as an non EU citizen? I
thought most companies applied EU laws like data deletion and data download(at
leas Google did afaik) worldwide.

~~~
SpicyLemonZest
I think the article is talking primarily about the jurisdictional requirement
- sounds like they plan to domicile UK data in the US again.

~~~
vmateixeira
Just got this email

...

Your service provider and data controller is now Google LLC: Because the UK is
leaving the EU, we’ve updated our Terms so that a United States-based company,
Google LLC, is now your service provider instead of Google Ireland Limited.
Google LLC will also become the data controller responsible for your
information and complying with applicable privacy laws. We’re making similar
changes to the Terms of Service for YouTube, YouTube Paid Services and Google
Play. These changes to our Terms and privacy policy don’t affect your privacy
settings or the way that we treat your information (see the privacy policy for
details). As a reminder, you can always visit your Google Account to review
your privacy settings and manage how your data is used. If you’re the guardian
of a child under the age required to manage their own Google Account and you
use Family Link to manage their use of Google services, please note that when
you accept our new Terms, you do so on their behalf as well, and you may want
to discuss these changes with them.

------
ptah
UK is going from an influential partner in the EU to a US vassal state pretty
quickly

~~~
lm28469
They're kind of used to it, they went from the most powerful empire in the
world to a tiny island without much going on for them in like 300 years, not
sure how much lower they could go at that point, I guess Ireland &co could get
independent in the near future.

At least they have their own independence day now.

~~~
Jestar342
UK will breakup soon. It's quite possible there will be a (separate) Great
Britain and Ireland in our life times, maybe even a separate Scotland, too.
"England & Wales" would be all that's left. "E-double-U". Heh.

------
arrivance
Per Wikipedia [1]:

Under section 3 of the European Union (Withdrawal) Act 2018,[2] the GDPR will
be incorporated directly into domestic law immediately after the UK exits the
European Union.

[1]:
[https://en.wikipedia.org/wiki/Data_Protection_Act_2018](https://en.wikipedia.org/wiki/Data_Protection_Act_2018)
[2]:
[http://www.legislation.gov.uk/ukpga/2018/16/section/3/enacte...](http://www.legislation.gov.uk/ukpga/2018/16/section/3/enacted)

~~~
jason0597
So much for "we get to write our own laws" as per the Brexiteers. We'll just
copy paste EU laws! I wonder how long it will take for those laws to be
removed

~~~
blibble
what exactly did you expect on day 1: a complete redesign of hundreds of
thousands of pages of laws?

over time UK law will diverge from EU law (in the same way that US law
diverged from UK law after 1776)

~~~
Barrin92
UK law won't diverge from EU law if the consequence is loss of access to or
friction with the European common market. The difference between the UK and
the US in your comparison is that the US turned into the world's largest
economy and sole superpower. The UK's economy is smaller than that of
California.

Realistically you can only write your own laws if you're the top dog.

------
itqwertz
Does this mean the end of the cookies pop ups?

~~~
osrec
Those were the most poorly conceived things in the history of tech
legislation. They literally solved nothing.

~~~
yread
Some websites don't use third party cookies or trackers so they don't have to
show the popup. Like mine

~~~
eh78ssxv2f
There might be a small subset of websites that do not show popup. However, the
question is whether the users adjust their browsing behavior based on those
popups or not? If the users have just become acclimatized to clicking on them,
then the situation has not really changed in any meaningful way.

~~~
maest
Dunno, I always opt out. It's not that hard to do, really.

~~~
osrec
Even when you opt out, do inspect your cookies. You'll be surprised as to how
many are still there, solely for the purposes of tracking.

~~~
atoav
Which is illegal.

------
neilwilson
I'm pretty certain the article is misinformed. The GDPR transfer regime still
applies in the UK, as it does in the EU. Google would have to implement the
"Privacy Shield" mechanisms by which EU or UK data can be transferred legally
to the US. The law in the UK remains the same as the EU. There is no
divergence at present. If Google has got the Privacy Shield system set up,
then any EU or UK data can be transferred to it. Chapter 5 of The Data
Protection Act 2018 refers
[http://www.legislation.gov.uk/ukpga/2018/12/part/3/chapter/5](http://www.legislation.gov.uk/ukpga/2018/12/part/3/chapter/5)

~~~
PaulRobinson
The article explicitly states Google is pre-empting the UK diverging
significantly from EU law in order to get a trade deal with the US.

I don't think that's a bad bet given that Downing Street is keen to make clear
food standards and the NHS are also up for grabs.

If anything, data protection is so badly understood as being important to
ministers, it would not surprise me if they trade it away in order to protect
food standards and the NHS because they're more prevalent in the headlines and
scarier to the over-50s that predominantly voted for Brexit and this
government.

~~~
squiggleblaz
It's true, it's weird the NHS should be up for grabs considering it's older
people who would be most hurt by changes to the NHS who voted for the Brexit.

But it's also a bit weird. I mean, I guess the issue with the NHS is drugs.
Australia has long had policies the US doesn't like, like the single purchaser
PBS and parallel imports. But we still have a FTA with the US.

~~~
neilwilson
The NHS isn't up for grabs, never has been and never will be. It's just a
scare story with zero foundation. Classic truth by repeated assertion.

~~~
BrockSamson
The same was said about the single market, we're leaving that now contrary to
statements by: Owen Paterson Daniel Hannan Nigel Farage Matthew Elliot Arron
Banks

I believe they called it project fear

------
adamcharnock
How precisely does Google determine which of its users are UK users?

For example, I lived in the UK when I opened my Google account(s), but now I
live in Portugal. Do I need to inform Google of this somehow. Do they look at
my payment information, or at my recent logins? I certainly cannot see any
'what country do you live in' options in my account settings.

I'd certainly prefer to keep any EU data protections should I have the choice.

~~~
andy_ppp
They literally know what colour your front door is, let alone which country
you are currently in...

------
andyjpb
Given that the UK is "intending" to follow GDPR and, for now, it is still
enshrined in UK law, this initially seems like a bit of a sensationalist scare
piece.

However, the lede is somewhat buried:

“There’s a bunch of noise about the U.K. government possibly trading away
enough data protection to lose adequacy under GDPR, at which point having them
in Google Ireland’s scope sounds super-messy,” Kissner said.

It's _possible_ that, over time, the UK will adjust its laws and lose EU
"adequacy". This currently seems unlikely so the game, from Google's point of
view, is to work out whether to move out early and cause a sensation or to
wait until it happens (if it happens) and then make a rush then.

It's complicated because things may change gradually, over a long period of
time, and there may be some things that are advantageous earlier or later.
Also, Google might not want to put itself in a position where it appears to be
trying to influence British law: "if you change that particular thing, we'll
move out". If they do it up-front under the guise of Brexit then they put
themselves in the best possible position to use the data as they wish (within
whatever law applies) and avoid such accusations later.

This is complex and involves a lot of game theory.

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w_t_payne
This move will make it considerably easier for influence shops to shape public
opinion in the UK and could help open up e.g. healthcare markets which are
currently closed.

------
darkwater
So, what can all the pro-FB/Google shills say about this? Wasn't GDPR,
according to them, a god-send for Google, FB and Big Tech because smaller
companies cannot possibly comply, while they can easily do? If that were true,
why are they moving their users out of GDPR reach at the first chance?

~~~
dazc
...because smaller companies cannot possibly comply, while they can easily do?

Smaller companies don't really need to comply since the possibility of
prosecution is negligible.

Big companies do because the possibility of prosecution is almost certain.

------
Havoc
That would seem pretty self-evident, no?

~~~
rwmj
No. During the current transition period there's a treaty which (to paraphrase
the situation greatly) causes the UK to be treated as if it was in the EU.
What happens when that ends (on 31st Dec 2020) is not yet clear, despite the
large amounts of noise being made by the UK government. It will depend on what
deal if any is struck before then.

~~~
barnaclebuster
It's much more likely to depend on what UK legislation is in force. Right now
there is UK legislation to enact GDPR and that does not simply disappear
because the UK left the EU. Unless new laws are passed, whatever is on the UK
statute books remains unaltered.

~~~
PaulRobinson
The article calls out that Google are betting that they will introduce new
laws with lower protections to get trade deals with the US, and so they're
getting ready for that now.

That is not a bad bet given briefings from Downing Street on trade deals.

------
rezeroed
Google to lose users in UK.

------
thefounder
We will get Boris protection!

~~~
DyslexicAtheist
we'll get exactly what we deserve

~~~
squiggleblaz
Democracy works slowly. You don't get what you deserve at each election.
Indeed, you can get utter slime without realising it till later.

------
ReptileMan
One can only hope. Big EU initiatives are two types - first prove that road to
hell is paved with good intentions, the other are similar to Herod reforming
the preschool industry in Bethlehem.

GDPR is nightmare that has not improved anything except now we have to click
for both cookies and GDPR form. I don't feel protected by it, mostly annoyed.
And a lot of sites did the smart thing - just cut off access for EU ips -
thanks Brussels.

~~~
qmmmur
And that you are legally culpable for violating it's terms.

~~~
ReptileMan
I am talking from consumer perspective - nothing improved.

~~~
GordonS
Talking from the consumer perspective, I completely disagree - things have
very much improved. Google and Facebook now make available everything they
have on you, easily accessible. Companies now have to tell me why they are
asking for information and what they are going to do with it. I can ask
companies for all information they hold on me, and they have to comply.

This is a _big_ improvement - there is a sense of companies going from
hoovering up every PI data point they could, to treating PI as a liability.
That's a big deal.

~~~
squiggleblaz
We ask for your information to improve our service. We know that you opted out
by selecting the "opt out" button in your web browser, but we're going to
ignore that and try to trick you into opting in, since we're so special that
your generic opt out probably doesn't apply to us. We will make it hard to
identify which links are really buttons that you need to click to disagree to
increase the probability that you will accidentally agree or agree out of
frustration. If you don't agree, we'll make you sit through a two minute
spinner while we during which time we do nothing since it takes no time at all
to save a cookie on your computer that says "don't save any cookies".

I mean seriously. If the GDPR had any teeth, the companies that do this shit
would be made to suffer. But since all they do is make us suffer and the EU
dgaf I wonder what the point is. It's just so much privacy theatre.

Maybe there's a shift somewhere. But I can't feel it as a user.

~~~
anoncake
Privacy _is_ the point but enforcement is very much lacking. The GDPR is
supposed to be enforced by the member states so the EU is not to blame – at
least if by "EU" you mean the EU bodies. The EU as a whole, including its
members and citizens may be but imo it's more accurate to say that it isn't
coherent enough to actually have opinions.

------
gowld
> Google is planning to move its British users’ accounts out of the control of
> European Union privacy regulators, placing them under U.S. jurisdiction
> instead, sources said.

Did the author mean "US", or "UK?

This article seems confused. I don't think the author knows what they are
writing about.

~~~
Seenso
> Did the author mean "US", or "UK?

> This article seems confused. I don't think the author knows what they are
> writing about.

They meant US, and the authors clearly weren't confused:

> If British Google users have their data kept in Ireland, it would be more
> difficult for British authorities to recover it in criminal investigations.

> The recent Cloud Act in the United States, however, is expected to make it
> easier for British authorities to obtain data from U.S. companies. Britain
> and the United States are also on track to negotiate a broader trade
> agreement.

~~~
lonelappde
But the UK still has jurisdiction over companies the operate in the EU.

------
Koremat6666
This is not a big deal, this gives UK freedom to make their own laws more
suitable to UK rather than laws made in Brussels. In a twist to the headline
we could also say tech companies around the world are in a better position to
push their innovations in UK without the red tape of EU.

