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Privilege across the pond: US vs. UK

Privilege allows and encourages frank communication between lawyers and their clients.  Whether you are dealing with a DSAR or a security incident, privilege often comes up and managing investigations on a multinational scale can be complex and time consuming.  It doesn't help matters when different rules may apply to different documents, and a privileged document in England and Wales may not be privileged in the US!

We have designed a table which summarises the similarities and differences in relation to privilege in England and Wales versus the US, as well as a recap on the concepts.  Click here to check it out.


data protection, gdpr, privilege, entertainment & media