By Justin Cornish, Alice Marsden, Brian Meenagh

On February 26, 2012 the Office of the Commissioner of Data Protection (OCDP) for the Dubai International Financial Centre (DIFC) published its Strategic Plan for 2012-14. One of the key statements in the Strategic Plan is the statement of the OCDP’s intention to apply to the European Commission for acceptance of the DIFC as a jurisdiction with an adequate data protection regime. If the DIFC is officially declared ‘adequate’ by the European Commission