News & Analysis as of September 27, 2024

Information Commissioner's Office (ICO)

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Follow this channel for updates and analysis on all aspects of the European Union's General Data Protection Regulation, a reform of EU's data protection rules that impacts individuals throughout the Union and all businesses operating therein. less -

UK ICO Unveils New Fine Calculation Guide for Data Protection Infringements

Latham & Watkins LLP on 4/11/2024

Understanding the ICO’s approach to assessing financial penalties should be a key element of an organisation’s data protection strategy and risk profile. In an era when data protection infringements can tarnish business...more

ICO’s call to action for UK website cookie banners

Hogan Lovells on 2/1/2024

The UK Information Commissioner’s Office (ICO) has recently published an update on its enforcement efforts in respect of website cookie compliance. It follows a letter the ICO sent in November 2023 to 53 of the top 100 UK...more

Generative AI - Data Privacy's Friend or Foe?

Katten Muchin Rosenman LLP on 1/29/2024

There’s so much activity around generative AI! This is a hot topic for us data privacy folks as it presents new challenges for the protection of personal data. Call us sad, but we get very excited about it!...more

Landmark Decision Handed Down on ICO’s Responsibilities in Handling Subject Access Requests

Cooley LLP on 10/25/2023

On 10 October 2023, the England and Wales Court of Appeal handed down its decision in Delo, R. (On the Application Of) v. The Information Commissioner1, in which it upheld an earlier High Court ruling that the UK’s data...more

ICO's Open Letter to UK Finance: A Call for Responsible Data Sharing in the Gambling Industry

Morgan Lewis - Tech & Sourcing on 9/6/2023

In recent years, the gambling industry has seen significant growth, with online betting and gaming platforms becoming increasingly popular. However, this rapid expansion has also raised concerns about the potential for money...more

Neurodata, Neurotechnology and Data Protection in the UK

Orrick, Herrington & Sutcliffe LLP on 8/25/2023

The UK Information Commissioner’s Office (“ICO”) has published a report on the evolving nature of neurotechnology and its implications for data protection laws. The report highlights the risks of neurotechnology and sets the...more

Increasing global cybersecurity regulation of private companies on the near horizon

A&O Shearman on 4/25/2023

Within the past year, a number of countries around the world, including the United States, United Kingdom, France, and The Netherlands have initiated regulatory inquiries and developed new strategies for the purpose of more...more

UK Information Commissioner’s Office Publishes Details of Reprimands

Cooley LLP on 2/10/2023

On 6 December 2022, the UK Information Commissioner’s Office (ICO) announced that it would publish details of all future reprimands, including those issued from January 2022 onwards, ‘unless there is a good reason not to’....more

The ICO Changes its Approach to the 24-Hour PECR Notification Rules: 5 Key Takeaways

Orrick, Herrington & Sutcliffe LLP on 2/6/2023

In what will be a surprise move to many, the ICO has issued a statement to UK public electronic communications service providers ("CSPs") regulated by the Privacy and Electronic Communications Regulations 2003 (known as...more

ICO Issues Updated Guidance on International Data Transfers

Orrick, Herrington & Sutcliffe LLP on 11/29/2022

On 17 November 2022, the Information Commissioner's Office (“ICO”) announced that it has updated its guidance on international data transfers. In its announcement, the ICO outlined its intention to “clarify an alternative...more

Reflections on six months in the ICO Legal Services Team

A&O Shearman on 9/2/2022

It’s 1 September 2022 and I’m back at my desk at Allen & Overy having spent the last six months on secondment to the Legal Services team at the UK Information Commissioner’s Office. So how did it go?...more

The Data Protection and Digital Information Bill: Taking Back Control of UK Data Protection?

Orrick, Herrington & Sutcliffe LLP on 8/4/2022

On 18 July 2022 the Data Protection and Digital Information Bill (the Bill) was introduced for discussion into parliament, in one of the UK's first drives towards data protection reform after Brexit....more

UK Information Commissioner’s Office Issues Warning on Ransomware Payments

Alston & Bird on 7/14/2022

On July 8, 2022, the UK Information Commissioner’s Office (UK ICO) together with the UK National Cyber Security Centre (NCSC), published a joint letter asking the Law Society of England & Wales to remind its members that they...more

UK Data: A New Direction – UK Government Responds to Consultation

Orrick, Herrington & Sutcliffe LLP on 6/30/2022

On 16 June 2022, the UK government’s Department for Digital, Culture, Media and Sport (“the DCMS”) published its response to its Data Reform consultation. The response sets out the UK government’s key data protection reform...more

The UK and global Data Protection landscape – seeing the bigger picture and navigating the maze

A&O Shearman on 6/16/2022

Introduction - The data protection landscape in the UK, and globally, continues to evolve. The pace and number of initiatives has continued into 2022. This requires a step back – to look for key trends and the most relevant...more

Privacy & Cybersecurity Update - May 2022

Skadden, Arps, Slate, Meagher & Flom LLP on 6/3/2022

In this month’s Privacy & Cybersecurity Update, we review Connecticut’s passage of a comprehensive privacy law (making it the fifth state to do so), the newly enacted federal Better Cybercrime Metrics Act, New York’s new law...more

The ICO’s First Ransomware Monetary Penalty Notice: Key Takeaways

Orrick, Herrington & Sutcliffe LLP on 3/16/2022

On March 10 2022, the UK Information Commissioner’s Office (ICO) handed down its first Monetary Penalty Notice in respect of a ransomware attack and data exfiltration incident under the UK General Data Protection Regulation...more

Data: A new direction?

A&O Shearman on 11/18/2021

As the UK looks to find a new and post-Brexit direction, the UK Government is setting its agenda for developments in regulation, particularly when it comes to technology, data and innovation. We have seen the recent...more

Proposed reform of the ICO – Necessary modernisation or a threat to independence?

A&O Shearman on 11/18/2021

The UK Government is currently consulting on its proposals for the UK’s post-Brexit data protection regime. The consultation paper, “Data - A new direction”, covers a wide range of ground, setting out to remove “unnecessary...more

ICO's proposals on UK international transfers may be simpler than the EU's approach but nevertheless remain onerous

A&O Shearman on 10/21/2021

When opening its recent consultation on regulating international data transfers from the UK in the post-Brexit era the ICO said, “We understand that international transfers can be complex, especially for smaller businesses....more

Hogan Lovells responds to the ICO consultation on international data transfers

Hogan Lovells on 10/8/2021

Hogan Lovells’ Privacy and Cybersecurity team have made a formal submission to the Information Commissioner’s Office consultation on how organisations can continue to protect people’s personal data when it is transferred...more

UK Employment Flash - September 2021

Skadden, Arps, Slate, Meagher & Flom LLP on 9/24/2021

In this issue of UK Employment Flash, we examine the latest employment law developments from the UK, including the law governing the return to the workplace and flexible working requests and a proposal to impose a duty on...more

Significant Changes Proposed to UK GDPR

Faegre Drinker Biddle & Reath LLP on 9/23/2021

On September 10, the U.K. government launched a consultation “Data: A New Direction” (Consultation), which proposes significant changes to the U.K.’s data protection framework. The U.K. government has signalled its...more

With the September 27 Deadline Looming, 7 Key Things to Know About Europe’s New Standard Contractual Clauses (SCCs)

Orrick, Herrington & Sutcliffe LLP on 9/9/2021

On June 7, 2021, the European Commission (Commission) published its long-awaited Implementing Decision adopting standard contractual clauses for the transfer of personal data to third countries referred to as the new Standard...more

Warren v DSG Retail Ltd – Shifting the Liability Landscape in Post‐Cyberattack Litigation

Orrick, Herrington & Sutcliffe LLP on 8/19/2021

Since the General Data Protection Regulations ("GDPR") came into force in 2018, companies in the United Kingdom (UK) that have suffered cybersecurity attacks often face civil claims from individuals whose data has been...more

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General Data Protection Regulation (GDPR) › Cybersecurity › Information Commissioner's Office (ICO)

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