Change to REC for Data processing outside of EEA
Summary
There is an added layer of authorisation to the processing of data outside of the European Economic Area (EEA) which provides no value to the process. The issue is specifically around 20.8) point a) which requires REC Board Approval prior to any processing.
Latest update and next planned activity
Date of latest update
Latest Update
This Change Proposal was implemented as part of the 7 November 2025 REC Release.
Impacts Overview
Impacted REC Documents
REC Main Body
Priority and rationale
Standard
Priority last updated on 29 May 2026
Solution development
Problem Statement
This Issue was raised by RECCo’s Data Protection Officer who noted that the addition of the extra layer of approval delays the process for Parties in processing this data, and it does not align with similar changes for the Balancing and Settlement Code (BSC), where board approval is not required.
No documents available.
There is currently no Change Plan.
Original submission
Change details
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13 May 2025
Change details
Change to REC for Data processing outside of EEA
There is an added layer of authorisation to the processing of data outside of the European Economic Area (EEA) which provides no value to the process. The issue is specifically around 20.8) point a) which requires REC Board Approval prior to any processing.
The addition of the extra layer of approval delays the process for parties in processing this data, and it does not align with similar changes for the BSC where Board approval is not required.
The approval does not do anything to mitigate any additional risks to the organisation. It is proposed that 20.8) point a) is removed, whilst retaining the remaining sub-clauses as they are relevant to managing the associated risks and UK GDPR obligations.
All parties are subject to UK GDPR and the remaining sub-clauses cover this, the clause being removed has no impact on the risk or obligations associated with the processing of data outside of the EEA.
Impacts
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Other (please provide details in Additional information box below)
This affects only the parties looking to process outside of the EEA. Parties will still need to adhere to UK GDPR and the obligations to protect consumer data, this will not change that.
REC Main Body
20.8) a)
has first obtained the REC Board's approval (on behalf the REC Controllers collectively); and
has first obtained the REC Board's approval (on behalf the REC Controllers collectively); and
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Priority & timing
No
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Other (please provide details in the Additional information box below)
Activity
Implementation Date has been updated to 07 Nov 2025.
florentina.monea has been allocated as Lead Analyst.