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Information Commissioner's Office (ICO) Data Protection Corporate Counsel

Skadden, Arps, Slate, Meagher & Flom LLP

Cookie Consent: Unpacking the UK ICO’s Proposed New Approach to Online Advertising

- What is new: The ICO is proposing to relax its enforcement of cookie consent requirements, meaning user consent would not be required for lower-risk advertising cookies. - Why it matters: The proposals aim to address...more

Paul Hastings LLP

ICO Annual Report Provides Insight Into Data Protection Risks for Businesses

Paul Hastings LLP on

The UK Information Commissioner’s Office’s (the ICO’s) latest Annual Report summarises its accomplishments and priorities, including last year’s enforcement actions. Based on our review of the report, we see the ICO focusing,...more

A&O Shearman

Data (Use and Access) Act gets Royal Assent

A&O Shearman on

On June 19 2025, the Data (Use and Access) Act (DUA Act) received Royal Assent, having passed both Houses of Parliament on June 11 2025. The Data (Use and Access) Bill was first introduced in the House of Lords on October 23...more

Jenner & Block

Client Alert: New GDPR Investigations into the Use of Children’s Data

Jenner & Block on

The UK’s data protection regulator, the Information Commissioner’s Office (ICO), has recently announced investigations into three companies in connection with the use of children’s personal information. In a statement on...more

Troutman Pepper Locke

U.K. Information Commissioner Issues New Guidance on the Use of Biometrics in the ‎Workplace

Troutman Pepper Locke on

On February 23, 2024, the Office of the Information Commissioner (“ICO”), the U.K.’s data privacy regulator, issued new guidance for employers about the use of biometrics in the workplace. Along with this new guidance, the...more

Cooley LLP

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

Cooley LLP on

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

Cooley LLP

New UK Guidance on Workplace Monitoring

Cooley LLP on

On 3 October 2023, the UK’s Information Commissioner’s Office (ICO) published new guidance on workplace monitoring. The previous guidance was issued in 2011, as part of the ICO’s Employment Practices Code, and was badly in...more

Orrick, Herrington & Sutcliffe LLP

Data Subject Access Requests from Employees: What UK Employers Need to Know About New ICO Guidance

A challenging economic situation is prompting contentious staffing decisions. The rise of hybrid work has led employers to generate more information in more places about employees. Against this backdrop, more employees are...more

A&O Shearman

Increasing global cybersecurity regulation of private companies on the near horizon

A&O Shearman on

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

Orrick, Herrington & Sutcliffe LLP

ICO Issues Updated Guidance on International Data Transfers

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

Orrick, Herrington & Sutcliffe LLP

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

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

Vinson & Elkins LLP

Patchworking Data Protection Regimes: UK Adopts New Data Transfer Mechanisms Post-Brexit and Schrems II

Vinson & Elkins LLP on

Two new United Kingdom (“UK”) data transfer mechanisms, the International Data Transfer Agreement (“IDTA”) and the International Data Transfer Addendum (“UK Addendum”) to the European Union’s (“EU”) new standard contractual...more

Faegre Drinker Biddle & Reath LLP

Significant Changes Proposed to UK GDPR

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

Orrick, Herrington & Sutcliffe LLP

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

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

A&O Shearman

European Commission adopts positive UK adequacy decisions for data transfers

A&O Shearman on

On 28 June 2021, just two days before the interim EU-UK data transfer “bridging mechanism” expired under the Trade and Cooperation Agreement, the European Commission (EC) adopted two adequacy decisions for the UK to...more

Orrick, Herrington & Sutcliffe LLP

Brexit Privacy Guide: Five Things You (Might) Have to Think About Before 2021

With the end of the Brexit transition period rapidly approaching and the United Kingdom (UK) poised to become a “third country” after it leaves the European Union (EU), the UK and the EU have yet to reach any “deal” on how...more

Orrick, Herrington & Sutcliffe LLP

Marriott Secures 80% Reduction in ICO Fine, but Here’s What You Missed…

Hot on the heels of the £20 million fine issued to British Airways, the Information Commissioner’s Office (“ICO“) has issued Marriott International Inc. (“Marriott“) with a long-awaited penalty notice for its failure to...more

A&O Shearman

What Might The BA And Marriott Fines Tell Us About The ICO’s Approach To Penalties?

A&O Shearman on

Few will have been surprised that, when the ICO eventually published details of the BA and Marriott fines, the final penalties were very much lower than the £183+ million and £99+ million proposed in the original notices of...more

Faegre Drinker Biddle & Reath LLP

Marriott Cyberattack Fine Reduced as ICO Shifts Penalty Policy

On 30 October 2020, the UK’s data privacy regulator, the Information Commissioner’s Office (ICO) issued a final penalty notice (Penalty Notice) to fine the hotel chain Marriott International, Inc. (Marriott) for a GDPR data...more

Morgan Lewis - Tech & Sourcing

ICO GDPR Fines Reduced to £20m and £18.4m to Reflect British Airways and Marriott Mitigating Factors

The UK Information Commissioner’s Office (ICO) has recently handed down two of the largest fines relating to a data breach in UK history. In August 2018, British Airways (BA) was subject to a cyberattack which breached the...more

Akin Gump Strauss Hauer & Feld LLP

U.K.’s Data Protection Regulator’s Updated Guidance on “Empathetic and Pragmatic” Approach

On April 15, 2020, the Information Commissioner’s Office (ICO), the U.K.’s data protection authority, issued further guidance on its regulatory approach during the global COVID-19 pandemic. Following its March note that we...more

A&O Shearman

Data Protection and Brexit – Clearing Up Some Misunderstandings

A&O Shearman on

Now that Exit Day on 31st January is drawing close attention is focussing on what will happen during the transition period that will run from 31St January until the end of the year. ...more

Jones Day

Data Protection: Reducing the Risk of Disruption on a "No Deal" Brexit

Jones Day on

The Situation: The United Kingdom is due to leave the European Union ("EU") on 31 October 2019. Negotiations between member states of the EU excluding the United Kingdom ("EU27") and the United Kingdom are ongoing, but it is...more

Fox Rothschild LLP

UK Data Protection Agency Issues New Guidelines for Data Sharing

Fox Rothschild LLP on

The United Kingdom’s Information Commissioners Office (ICO) has issued, for public consultation, draft guidelines for data sharing that—once adopted —will govern all controller-to-controller data sharing agreements which are...more

McCarter & English, LLP

Data Privacy Gets Pricey: First Enforcement Outside The European Union

The other GDPR shoe has dropped… with the European data protection law being enforced against a Canadian company. Since the sweeping law went into effect on May 25, 2018, the digital world has been waiting for enforcement...more

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