Our internal position on GDPR and Brexit was, on 27th June 2016:
The key thing, from a practical point of view, is that negotiations to leave the EU are unlikely to be completed before – at the earliest – October 2018. GDPR comes into force from May 2018. UK continues to be fully bound by EU treaties and rules up to the point where it ceases to be a member.
GDPR compliance therefore remains an issue for all UK businesses.
Once the UK leaves the EU, those UK companies processing EU personal data will be in the same position as other non-EU processors – required to appoint a representative within the EU (pursuant to Article 27).