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Data Processors United Kingdom Information Commissioner's Office (ICO)

Goodwin

The Data Shift: UK Sets a New Course With 2025 Data (Use and Access) Act

Goodwin on

The Data (Use and Access) Bill passed both Houses of UK Parliament and received Royal Assent on 19 June 2025, now becoming the Data (Use and Access) Act 2025 (“DUA Act”). This is the final iteration of the Data Protection and...more

Latham & Watkins LLP

EDPB Issues Guidelines on Processing Personal Data for Legitimate Interests Purposes

Latham & Watkins LLP on

The draft guidelines provide further clarification to the EDPB’s interpretation of legitimate interests, and suggest a potential divergence with the UK ICO....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Bill in U.K. Parliament Would Facilitate Certain Types of Data Processing by Redefining ‘Personal Data’ Parameters

On March 8, 2023, the Data Protection and Digital Information (No. 2) Bill was introduced to the UK Parliament by the Department for Science, Innovation and Technology (DSIT). If enacted, the Bill will make changes to the UK...more

Epiq

International Data Transfers: Knowing Which Rules Apply to Comply

Epiq on

While countries all over the globe continue to make data privacy strides, comparing similarities and differences between the EU and U.K. is important in light of Brexit. It is also crucial to know the differences as they...more

Latham & Watkins LLP

UK Data Protection Bill: Examination of Key Provisions (Part 2)

Latham & Watkins LLP on

Areas of interest include anonymisation, “recognised legitimate interests”, and the ICO’s role. The UK Data Protection and Digital Information Bill (the Bill) sets out the government’s proposals for reforming the current...more

Latham & Watkins LLP

UK Data Protection Bill: Overview of Proposed Changes (Part 1)

Latham & Watkins LLP on

The bill would largely build on the UK data protection regime’s EU GDPR-style framework, albeit with UK-specific provisions. The UK government introduced the Data Protection and Digital Information Bill (the Bill) to...more

Orrick, Herrington & Sutcliffe LLP

6 Things You Need to Know About United Kingdom (UK) International Data Transfers

In February 2022, the United Kingdom (UK) Information Commissioner’s Office (“ICO”), along with the data protection authority (“DPA”) in the UK, published three new documents ("UK Documents") which update the UK's position on...more

A&O Shearman

Data: A new direction?

A&O Shearman on

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

Goodwin

Europe OPTS for Pragmatism with New SCCS and ICO Opens Consultations on UK SCCS — What Companies Need to Do Next

Goodwin on

The dust has settled on the new EU standard contractual clauses for cross-border data transfers (“New SCCs”), but confusion still reins on how the New SCCs cover data transfers and what companies need to do to take advantage...more

BCLP

BCLP Global Data Privacy FAQs: Can the new EU standard contractual clauses be used for transfers of personal data from the UK?

BCLP on

The European Commission recently adopted new standard contractual clauses (SCCs) for transfers of personal data from the EU to “third countries” (the “new SCCs”). In this post, we highlight key developments in the UK’s data...more

Latham & Watkins LLP

New Standard Contractual Clauses and Final EDPB Recommendations - Next Steps

Latham & Watkins LLP on

Companies have three months to prepare to use the latest standard contractual clauses for new data transfers, and 18 months to migrate existing arrangements. On 4 June 2021, the European Commission released its...more

BCLP

Who, Sir? Me, Sir? Appointing GDPR Representatives in the UK and the EU

BCLP on

This article explores the topic of appointed representatives under Article 27 of the GDPR. What are they? When do you need one? How is regulatory enforcement starting to play out in the EU and in the UK on this issue?...more

BCLP

The Data & Brexit Digest - Data protection representatives

BCLP on

With the UK unambiguously out of the EU, this fourth and final installment of our Data & Brexit Digest explores the topic of appointed representatives under Article 27. What is an Article 27 representative? The...more

Katten Muchin Rosenman LLP

UK ICO Issues Guidance on COVID -19 Data Protection Considerations

The Information Commissioner's Office (ICO) has issued a statement confirming that data protection will not stop the need for businesses to share information quickly, or adapt the way they work to face the unprecedented...more

Orrick, Herrington & Sutcliffe LLP

Privacy in the Time of Coronavirus

Over the past few days, commentators and, in some cases, government ministers have stated that the GDPR (and by association the Data Protection Act 2018) are preventing some organisations from providing a comprehensive...more

Akin Gump Strauss Hauer & Feld LLP

AI Auditing Framework – Draft ICO Guidance Published for Consultation

On February 19, 2020, the Information Commissioner’s Office (ICO), the data protection regulator in the United Kingdom, launched a consultation on its draft guidance on the artificial intelligence (AI) auditing framework. ...more

Fox Rothschild LLP

UK ICO Provides Guidance On Processing Sensitive Information

Fox Rothschild LLP on

The United Kingdom's Information Commissioner's Office has updated its guidance on Special Category Data (Article 9 General Data Protection Regulation). Key takeaways: Genetic Data- Genetic analysis that includes enough...more

BCLP

Hotels and GDPR

BCLP on

We are now over a year on from the major changes made to the European data protection regime by the GDPR so it is time to revisit what the changes mean now for the hospitality sector and investment in it, given increased...more

WilmerHale

UK ICO Report Scrutinizes Adtech Industry, Focusing on Real-Time Bidding Systems, Threatens Sweep in Six Months

WilmerHale on

In recent months, the Office of the Information Commissioner of the UK (“ICO”) has been looking into how personal data is used in real time bidding (“RTB”) in programmatic advertising, involving key stakeholders, including in...more

Fox Rothschild LLP

GDPR Guidance: Data Controllers Are Responsible For Processors’ Competency

Fox Rothschild LLP on

The UK Information Commissioner’s Office (ICO) has issued a new guidance on the liabilities of Controllers and Processors, advising that the Controller is responsible for assessing that its Processor is competent to process...more

BakerHostetler

New Guidance on GDPR Data Processing Contracts Published by the UK ICO

BakerHostetler on

The U.K. Information Commissioner’s Office (ICO) recently published guidance on contracts between controllers and processors. This new guidance provides a more in-depth and detailed discussion of the key issues than did a...more

Fox Rothschild LLP

The ICO Speaks: New Guidance On Contracts, Data Controllers And Processors

Fox Rothschild LLP on

The UK Information Commissioner’s Office (ICO) has issued several new guidance documents on Data Controllers, Data Processors and the interaction among them....more

BCLP

GDPR: The Most Frequently Asked Questions: Is a Lawyer a Processor or a Controller?

BCLP on

The European Union's General Data Protection Regulation ("GDPR") is arguably the most comprehensive - and complex - data privacy regulation in the world. Although the GDPR went into force on May 25, 2018, there continues to...more

Pillsbury - Global Sourcing Practice

The ICO’s Draft Guidance Leaves Unanswered Questions on Processor Obligation to Notify Infringing Instructions

Those of us who have been grappling with how best to approach GDPR compliance in outsourcing and other commercial contracts will be all too familiar with Article 28 of the GDPR, which sets out a number of minimum contract...more

Morgan Lewis

ICO Offers Guidance for Contracts under the GDPR

Morgan Lewis on

Earlier this month, the United Kingdom’s Information Commissioner’s Office (ICO) released an initial draft guide of contracting requirements and liabilities for data controllers and data processors doing business together...more

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