
Norway’s Datatilsynet does not mince words in its Brexit guidance:
“On 31 December 2020, the Brexit transition period will end. This means, among other things, that anyone who transfers personal data to the United Kingdom after this date must follow the rules on the transfer of personal data to third countries.”
“If the European Commission does not give the UK an adequacy decision before the New Year, companies that transfer personal data to the UK must ensure a transfer basis and comply with the additional terms of the Schrems II ruling if they are to continue transferring personal data after 31 December.”
Both data transmission and remote access are considered as the transfer of personal data.