Crown Worldwide Group

Making sense of BrexitHelping our clients prepare

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ContentsThe landscape ............................................................................................................................................................3

The implications for managing your data and information .....................................................................4

The storage and transportation of Fine Art ................................................................................................7

Mobility within Europe ........................................................................................................................................ 10

Planning on relocating? ......................................................................................................................................... 11

Conclusions .............................................................................................................................................................. 13

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The landscapeMore than three years after the United Kingdom voted narrowly in favour of leaving the European Union, the nature and timing of the UK’s exit from the EU still remains uncertain. In the years that have passed, two changes of Prime Minister have ensued and the original anticipated exit date of March 29th has long since passed. As we head towards the extended exit deadline date of October 31st, the prospect of a “no deal” Brexit has become more of a possibility despite those politicians in opposition seeking to legally rule out this option. With no obvious signs of breakthrough following the defeat of Teresa May’s proposed exit deal on several occasions, what is clear is that businesses have had to step up their plans and preparations to deal with the implications of “no deal”.

At Crown Worldwide, we have monitored the political situation for a considerable period of time, and like many organisations have created a Brexit strategy. This strategy not only incorporates our own contingency plans to address the challenges that Brexit will bring to our various businesses, but also seeks to address the needs of our clients and customers. This document outlines our position for all of our brands and businesses.

In this document, we look to give you confidence in these uncertain times.

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The implications for managing your data and information

Risks in managing your dataFor many UK-based organisations, the implications are likely to be minimal. Nonetheless, you should treat Brexit as an opportunity to evaluate the way you manage your data, ensure you don’t have any vulnerabilities and think about any improvements.

For us, it boils down to one key point: General Data Protection Regulation (GDPR).

By complying with GDPR, and understanding the details of your GDPR compliance, you should be well-prepared for Brexit – whatever form it may take.

How GDPR fitsLast year, the introduction of GDPR imposed the same strict requirements on every country in the EU – as well as every organisation operating in the EU, and every organisation that holds any personal data relating to EU citizens.

GDPR also enables data to be shared and transferred between all EU countries. However, the same data cannot be transferred to a ‘third country’, unless the EU believes that country has adequate data protection rules in place. Once Brexit materialises, the UK will become one of those ‘third countries’.

Once Brexit takes place (irrespective of how hard or soft it may be), we know that GDPR will be incorporated into UK law. So, in practice, the way you manage your data and documents will need to continue to comply with EU requirements. In all likelihood, the EU will formally state that the UK regulatory regime offers adequate protection (a little like the Privacy Shield arrangements between the EU and the US).

However, we don’t know for sure what the EU will say, and we don’t know what timescales may apply. So, from a data and document management perspective, that’s the big Brexit uncertainty. Our overwhelming advice is to manage your data to GDPR EU standards.

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Practical implications for domestic and multi-national organisationsEven if you are a purely domestic organisation, which only does business in the UK and stores all its data in the UK, you should still give the matter some thought. If you hold any personally identifiable information (PII) on any EU citizens (such as employees, customers or suppliers), you will still need to abide by the EU’s requirements. By complying with GDPR, you should be adequately covered.

For a multi-national organisation, especially one that stores and/or transfers data across borders, the situation is going to be more complex. The key is to understand exactly what data you store, where it is stored, how it is transferred, and how it is protected. Again, we believe that the EU is likely to say that the UK regulatory regime offers adequate protection, which would enable you to continue to operate in the same way. However, you may want to put some additional safeguards in place. For example, smaller companies may want to introduce new contractual clauses, whereas multi-nationals may want to update their binding corporate rules.

The UK Information Commissioner’s Office (ICO) has produced a useful guidance document that talks through this challenge.

For more information please visit https://ico.org.uk/ for up to date information.

Storing physical documents in EuropeOur Records Management business operates in over 40 countries worldwide and, in our experience, it’s very rare for firms to store physical documents offshore. If you do happen to fall into that category, this is a good time to relocate them. There’s no major urgency to do so, but it makes business sense to plan for it. Crown has Records Management centres across the whole of the UK, from the Channel Islands in the south, to Livingston in the north with major centres within the M25 and across the M62 corridor. We service major cities throughout the length and breadth of the country, providing daily services from strategically located facilities both for domestic and multi-national customers. Therefore, we do not envisage any issues with delivering service to any clients. Globally, Crown operates from 40 countries and works in 29 different languages. We have limited capability in the USA, but have a sizeable presence in the Far East, including Hong Kong, China, Singapore and Vietnam, as well as New Zealand and Australia.

All of our facilities operate to the heighest security standards, Crown have been awarded the ISO 27001:2013, ISO 9001:2008, Cyber Security Plus ISO 37001 and the ISO 14001:2004 relating to our environmental credentials. Crown are proud to have sustainability as a key part of all our operations. An example of this is our outstanding facility in Peterborough, which contains 208 solar panels installed on its roof. In addition, all of the external lighting on the building and yard areas is LED controlled by day and night sensors.

Brexit poses many challenges, but Crown will continue to work as efficiently and eco-friendly as possible.

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Questions organisations should be asking themselves regarding records management as Brexit approaches.

Will data protection rules change as a result of Brexit?In the short-term, nothing will change. The government has already said that GDPR will be replicated in UK law when Brexit happens.

However, in the future, there may be some divergence. For example, there is a chance that the EU may update GDPR, and the UK may not follow suit with its domestic regulation. As a UK company, or a company with UK operations, you’re likely to be ahead of the curve, due to the UK’s reputation as a data protection pace-setter.

What are the implications of a no deal Brexit? For digital data, it’s unlikely that a no deal Brexit would have any additional impact.

Instead, the big implication of no deal would be to restrict the physical movement of people and goods – which is all the more reason to avoid the offshore storage of documents.

The UK government has issued its own advice as to how to prepare for a “no deal” Brexit with regard to sharing personal data across borders, which can be found at: https://www.gov.uk/guidance/using-personal-data-after-brexit#what-you-need-to-do-before-a-no-deal-brexit.

What practical steps should be taken to eliminate any risks?The most pertinent questions are: “Did I do my GDPR compliance rigorously?” and “What can I learn from the process?”

As a result of GDPR, you should already know what data you have, where it is located, how it is protected, and how it is transferred. Larger organisations and those that process lots of data will also have a Data Protection Officer who knows the intricacies.

The most practical steps are to go back to your GDPR compliance programme and look at everything through a ‘Brexit prism’ – by which we mean, understand what data is stored across EU and UK locations, and how it is transferred to or from the UK.

Using these steps, you should be well-positioned for Brexit (whatever form it may take), and be able to identify any necessary changes and protect yourself from any risks.

How can we alleviate the risks of Brexit?A key part of the Crown Records Management proposition is our Information Consulting Services, which means our teams can help clients with any challenges – including regulatory compliance and Brexit preparations. The key risks the records management industry may face relate to data retention. As part of Europe, the UK is governed by EU Legislation, legislation that relates to storing documents, GDPR, cloud security and much more. As a business, you may now opt to hold on to more data and store it just in case Brexit takes a drastic turn. This will have a knock-on effect on unnecessary data retention and property space. Crown can help you make sense of your data. We offer many services that will not only organise and categorise your data, but also offer agile workspace solutions to drive out costs and improve efficiency.

We can help with a full audit of your records and documents, identify any areas of risk, and help you achieve post-Brexit compliance.

As we said at the outset, you should treat this as an opportunity to take a look under the lid of your data, and consider how you could be doing things better. By taking a wider view on your Brexit preparations, our people will almost certainly find practical ways for your organisation to save money, reduce risk, and become more effective in managing paper, digital information and records.

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The storage and transportation of Fine Art

The impact of Brexit on collectorsWhilst we still don’t know what Brexit will entail, any individual desire to move art across borders, whether personally or as a loan to an exhibition, is likely to be affected. From small-scale collectors with minimal objects, to large-scale collectors with significant investments, we advise everyone to begin thinking about what Brexit could mean now.

Transport and storage of artThere’s a fear that a hard Brexit will mean new legislation and individual import/export agreements with countries. We have seen a rise in enquiries for artwork being moved until there is a clearer picture as to what is happening. Many collectors have kept art in the UK for a long time and are very reluctant to move it, or want to move it back into the UK. However, the growing trend of art being moved across borders is likely to continue as uncertainty remains.

Moving art from country to countryWe could see changes in the customs import tax rate on artworks being transported across borders. This would undoubtedly change buying habits and the way art moves, with also the possibility of incurring increased costs. However, the impact of these changes could depend on what final deal is struck. Nonetheless, in the event of a no-deal, museums and the government will continue to support the movement of art between the EU and the UK in the form of lending and borrowing for exhibitions.

Crown Fine Art has an array of experience handling, moving and storing art throughout Europe and overseas. We are currently able to pack, ship and deliver art to anywhere in the world in approximately 12 days or less – regardless of size or volume. Whilst this timescale may be affected by Brexit, we are confident that our unique position in the UK and Europe gives us a distinct advantage, and gives our client’s greater comfort. It will enable us to continue making the physical storage and movement of art simple and economical, regardless of what Brexit brings.

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Art provenanceIt’s vital for collectors to be able to provide provenance for each piece of art they own, and have a documented history of its movement and origin. While Brexit will not change this, a hard Brexit could mean all such related laws would have to be reviewed with individual countries. Faced with the possibility of being unable to move their art, even temporarily, collectors are looking at cross border storage as a short-term solution.

How can collectors prepare for Brexit?Whilst developing a comprehensive plan is virtually impossible until an actual deal is struck collectors can make basic preparations. These include ensuring all relevant paperwork (shipping notes, invoices, inventories and delivery documents) are up-to-date and in order. Time should be given to creating or updating the collection catalogue sooner rather than later, as this can be time-consuming. This is something Crown Fine Art can help clients to do.

How Crown Fine Art are handling BrexitFirstly, we are the only art handler to have its own designated storage facilities across mainland Europe. As such, we are best placed to hear concerns from collectors and businesses across the region. These European storage facilities enable us to be a one-stop storage and transport company for many clients. Whilst we still don’t know what Brexit will entail, in the event of a no-deal, museums and the government are putting plans in place.

This is to ensure the continued support of the movement of art - in the form of lending and borrowing - for exhibitions between the EU and the UK. Secondly, being an agile company allows us to quickly adapt to market changes, with country managers meeting regularly to discuss issues like these.

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Storing art ahead of BrexitA growing number of collectors are considering where best to store their collection until legislation becomes clearer. However, many are finding planning difficult and are questioning where they should store their art and what access they will have. Our extensive storage network means our clients can store their art in locations of their choice. They can easily transport it between different countries and facilities, including the Middle East and Asia.

Store your artwork with Crown Fine ArtBrexit aside, one of the biggest benefits of storing art is the peace-of-mind it provides. Collectors know their art is safe and secure, but access to it is easy whenever needed. They can also continue collecting without the worry of running out of space, and when they need to move pieces for whatever reason, all of the logistics are expertly managed.

For extra peace of mind, all of our facilities are of the same quality and have ‘bonded’ customs status, where import taxes can be suspended indefinitely. State of the art security, restricted access, and humidity and temperature controls ensure our clients’ works of art are kept safe and preserved at all times.

Services provided at Crown Fine Art storage facilitiesCrown Fine Art has, and takes, complete control over all its storage facilities. We ensure each client has a dedicated single point of contact, and advice tailored to their needs. Everything we do adheres to security and environmental protection standards, whilst our exclusive viewing rooms provide an added bonus. With no communal spaces, we guarantee complete privacy at all times, which eliminates the need for constant chaperoning whilst on-site. As well as offering private viewings and sales facilities, we can also create insurance reports and conduct photography on-site.

Concerned about Brexit?Speak to us. We’d be more than happy to discreetly help any collector with impartial, expert advice without obligation. We’re constantly monitoring the likely impacts of Brexit as things develop, so for the latest advice, please do get in touch.

Mobility within EuropeWhat’s the immigration impact and your advice?Brexit will impact all EU nationals living and working in the UK, and UK nationals living and working in the EU member states. The Free Movement of People Agreement will no longer apply to these individuals. They may need to adjust their immigration status according to the rules applicable to non-EU citizens, such as Americans and Canadians.

We highly recommend that companies conduct internal audits and identify employees that will be affected – if that hasn’t already been done.

Whilst we cannot be 100% certain, we anticipate that the deal would prescribe a grace period and different lateral agreement to facilitate the movement of people within the region. This will allow companies to apply for, and change the work permit categories of their employees, hopefully without disrupting operations.

Brexit: Immigration if there is no dealThe U.K. is not the only country affected if it exits the EU with no deal. EU nationals are entitled to Freedom of Movement and do not require a permit to live and work in other EU countries. However, when the U.K. leaves the EU, its nationals’ immigration status will change to that of an unprivileged third-country national. By law they will require a visa or permit to enter the Schengen Area and work in an EU country.

Several governments have published plans that will take effect after Brexit, the new withdrawal date has been set as 01 November 2019, 00:00 CET. We have looked what EU countries are doing to minimize the impact of a no-deal outcome on U.K. citizens planning to work and reside in the countries.

For more information on this please click here https://www.crownworldmobility.com/insights/brexit-on-october-31-2019-immigration-if-there-is-no-deal-2/

EU nationals residing or planning to reside in the U.K.Only the rights of EU nationals living in the U.K. before 31 October 2019, will be protected. The EU Settlement Scheme will still operate, however, the cut-off dates will be brought forward. EU citizens in the U.K. before 31 October 2019 will qualify, and will be required to apply before December 31, 2020.

What are companies doing at the moment?Most companies in the UK are in a “wait-and-see period.” Their entities and affiliates around Europe continue to monitor political developments closely as the post-Brexit environment is still uncertain. However, we sense that the majority of business entities plan on continuing operations in the UK. Leadership teams are also assessing additional jurisdictions to incorporate, where there are no restrictions to non-EU entities. Most companies appear to be keeping their headquarters in England and Wales, but this may change in the near future.

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Planning on Relocating?Assurances of moving with Crown RelocationsOperationally, our warehousing and service partners are prepared with the required permit and customs approvals. Our staff are being trained on customs requirements for EU countries, where previously customs was not a consideration. We’ll be able to answer all questions you have regarding your items along the way.

Challenges to be aware ofThe biggest potential challenge will be if the UK leaves the EU with a hard Brexit. This could affect the requirements for import and export shipments to and from the UK and Europe requiring an additional customs clearance. In this event, we are operationally prepared to store your items in our warehouse as bonded imports, or hold prior to export pending customs documentation preparation.

Understanding bonded storageCrown Relocations has bonded storage at our London facilities. In the event of a no-deal, your items can be brought from Europe to our storage facility until clearance has been undertaken. Alternatively, if you are relocating to Europe from the UK, we can hold your effects in-store prior to your relocation. Although this is not a necessary option for moves out of the UK, it does offer peace of mind that your items will be safely stored if changes to customs occur.

The effect on port haulageNo immediate impact is expected to seaport haulage services as a result of a no-deal Brexit, as very little sea freight is imported from the EU. However, the haulage industry employs a high percentage of drivers from the EU. Therefore, medium to long-term challenges may present themselves if driver availability is reduced.

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Cabotage and its impact on a no deal BrexitCabotage is the transport of goods or passengers between two places in the same country, by a transport operator from another country. Once the UK leaves the EU, cabotage restrictions may apply to UK based Crown vehicles and partners moving items between EU countries.

This may reduce the number of service partner options available to Crown Relocations. This could impact transit times and costs, as UK partners tend to be more abundant and economical than partners in other Western European countries. The UK government is seeking assurances that cabotage restrictions will not be applied on a reciprocal basis with the EU, but this is yet to be agreed.

Expected changes to transit times for entering the UK Transit times for anyone moving to the UK may be extended in the immediate term by up to 2 weeks. UK rules for Transfer of Residence relief requires the client to apply and seek approval prior to import. This can’t be undertaken until the UK is no longer a member of the EU. Crown UK can offer bonded storage in the short term whilst the application is being undertaken.

Things to be aware of:The Guardian recently listed out some helpful tips as you plan your moves to Europe:

• UK citizens will have to pay €7 for a travel permit in advance of travel, as part of the European Travel Information and Authorisation Scheme (ETIAS).

• The government is recommending that UK travellers have at least six months left on their passports from the date of arrival in an EU country.

• Pet passports are likely to be affected if a no deal Brexit is reached.

• UK-registered European health insurance cards (Ehic) may no longer exist after March 29th. Health insurance may be needed instead.

• Free data roaming for mobile phones are not guaranteed.

• Even in a no-deal scenario, the European Commission has said that UK airlines would still be able to operate flights between the UK and the EU.

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Crown is here to guide you through the twists and turns Brexit continues to produce. We are building certainty and clarity through tackling those difficult questions and anticipating your needs in the best way we know how.

The government has advised businesses to be prepared, and have a plan in place for the 9-10 months post Brexit. There are many parts in play, and Brexit is a realistic and fast approaching change to the UK and Europe. As politicians go back and forth on varying forms of Brexit deal and consider the impacts to industries and businesses in the UK and EU, you need to do the same. Take some time to think about operations, customer service and planning. Crown is here to help you navigate through Bexit.

Don’t waste any time. Plan your Brexit strategy today with the help of Crown, keep your business ahead, and be confident in your response to Brexit.

ConclusionPlease contact our expert Head of Businesses in the UK:

Crown Records Management David Fathers Regional General Manager dfathers@crownww.com

Crown Fine Art David Preston General Manager, Fine Art dpreston@crownww.com

Crown World Mobility Vicky Woods Head of Client Services and Crown Relocations Account Management, vwoods@crownww.com

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