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Privilege in Privacy Matters in the US and UK: A Comparison

The concept of privilege allows and encourages frank communication between lawyers and their clients. Whether you are dealing with a data subject access request (DSAR) or a security incident, privilege often comes up and managing investigations on a multinational scale can be complex and time consuming. This is especially the case given that different rules may apply to different documents and a privileged document in England and Wales may not be privileged in the United States.

We have designed a table to assist by providing a summary of the key similarities and differences in relation to privilege when dealing with these issues in England and Wales and the United States, as well as a recap on the concepts. Please download our comparison table for more information.