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Chronicles

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Sources: following Brexit, Google plans to move UK user accounts out of EU's jurisdiction and into the US', where privacy protections are weaker

SAN FRANCISCO (Reuters) - Google is planning to move its British users' accounts out of the control of European Union privacy regulators …

Reuters Joseph Menn

Context & Ripple Effects

This is the second act of a playbook Facebook already ran. In 2018, [[a:928697|Facebook rewrote its terms so that 1.5B users outside Europe fell under US rather than Irish terms]], cutting GDPR's reach to roughly 400M people — and in December 2020 it moved its UK users into agreements with its California headquarters rather than its Irish unit. Google is now applying the same jurisdictional carve-out to British accounts once Brexit takes them outside the EU's legal perimeter.

The move matters because account jurisdiction, not user location, determines which regulator can enforce privacy rules — a structure Google itself has engaged with before, as when it extended right-to-be-forgotten removals across all domains viewed from the EU.

First-order effects

  • British Google users shift from the oversight of Ireland's EU-anchored data protection authority to US-based terms, leaving them outside GDPR enforcement even before the UK establishes its own equivalent regime.
  • EU regulators' effective jurisdiction over Google shrinks to remaining member-state users, reducing the population whose complaints and rights requests they can compel Google to honor.

Second-order effects

  • With Facebook having set the template twice and Google following, every major US platform with an Irish legal entity faces pressure to redraw its user agreements along the same lines, making Ireland's role as Europe's data-protection gateway untenable.
  • The UK government must decide whether to match EU privacy protections to keep its citizens' coverage equivalent or accept divergence — a choice that shapes whether London becomes a regulatory rule-taker or rule-maker.

Third-order effects

  • If the pattern holds, data protection becomes a function of corporate contracting entities rather than geography, pushing the EU toward structural countermeasures like forced local processing — a direction visible in Google's own later expansion of EU sovereign-cloud options with a 'data shield' for European clients.
  • Brexit thus creates a durable two-tier privacy map across Europe, with enforcement capacity fragmenting along national lines unless the UK and EU negotiate mutual adequacy arrangements.

The trend: Post-Brexit, US platforms are redrawing user-account jurisdictions so GDPR coverage tracks corporate contracting entities rather than where users live, forcing regulators toward localization mandates in response.

Discussion

  • @gcluley Graham Cluley on x
    Timely reminder: Other search engines are available. https://www.theguardian.com/ ...
  • @uk_domain_names Edwin Hayward on x
    Looks like Google may be readying to transfer UK user accounts from Ireland to the US, which would take them outside the scope of the EU's GDPR regulations. Net effect will be much weaker privacy protection for us. (Move is Brexit-related, of course.) https://www.reuters.com/...
  • @cornwall4eu @cornwall4eu on x
    Google users in UK to lose EU data protection. Doesn't “taking back control” feel great? At last we have the freedom to let giant global corporations exploit our personal information without those pesky EU bureaucrats getting in the way. https://mobile.reuters.com/...
  • @slpng_giants @slpng_giants on x
    .@google never has to follow any government regulations because they are more powerful than any government. Good luck, UK. https://twitter.com/...
  • @travelfish Stuart McDonald on x
    “Beyond that, the United States has among the weakest privacy protections of any major economy, with no broad law despite years of advocacy by consumer protection groups.” https://mobile.reuters.com/... Taking back control...
  • @tha_rami Rami Ismail on x
    It's time for the Brits to take back contr-I mean place all their personal data into one of the most aggressively de-regulated privacy territories in the Western world, and that's true for US citizens, but even worse for the foreigners the Brits are now. https://www.reuters.com/.…
  • @blmohr @blmohr on x
    “The shift, prompted by Britain's exit from the EU, will leave the sensitive personal information of tens of millions with less protection and within easier reach of British law enforcement.” https://www.reuters.com/...
  • @zackwhittaker Zack Whittaker on x
    Wow. Seems about right. Per @josephmenn: “The shift, prompted by Britain's exit from the EU, will leave the sensitive personal information of tens of millions with less protection and within easier reach of British law enforcement.” https://www.reuters.com/...
  • @iainthomson Iain Thomson on x
    Sure, we lose data protection but BLUE PASSPORTS! https://twitter.com/...
  • @podehaye Paul-Olivier Dehaye on x
    This sounds inconsistent with the approach towards Switzerland https://www.reuters.com/...
  • @mikebutcher Mike Butcher on x
    Google is planning to move its British users' accounts out of the control of European Union privacy regulators, placing them under U.S. jurisdiction, leaving personal information of UK citizens with less protection and within easier reach of British law. https://www.reuters.com/.…
  • @andymcgeady Andy McGeady on x
    Wow. So very #BrexitShambles-predictable. But wow. https://twitter.com/...
  • @gavinsblog Gavin Sheridan on x
    Taking back control by losing control. https://www.reuters.com/...
  • @arashbahmani Arash Bahmani on x
    “Google is planning to move its British users' accounts out of the control of EU privacy regulators, placing them under US jurisdiction. The shift will leave the sensitive personal information of millions with less protection and within easier reach of British law enforcement”. h…