News & Analysis as of

United Kingdom Personal Data

Alston & Bird

The Digital Download – Alston & Bird’s Privacy & Data Security Newsletter – May 2025

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Selected U.S. Privacy & Cyber Updates - DOJ Settles False Claims Act Case with MORSECORP over Cybersecurity Program - On March 26, 2025, the U.S. Department of Justice (DOJ) announced that it had reached an agreement with...more

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

Navigating the Rise in Data Subject Access Requests

Recently, there has been an increase in individual rights activity across Europe, particularly organizations receiving Data Subject Access Requests (DSARs) from former employees. ...more

A&O Shearman

ICO reports findings of children's data protection in financial services

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The Information Commissioner's Office (ICO) has published its report alongside a press release following a review into the gathering and use of children's data in financial services, particularly from services supplying them...more

Alston & Bird

UK’s Data Protection Regulator Fines a UK SaaS Provider ~$4 Million Following a Ransomware Incident

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On March 26, 2025, the UK data protection regulator (the Information Commissioner’s Office (“ICO”)) fined Advanced Computer Software Group Ltd (“Advanced”) £3.07 million (approximately $4 million). In 2022, Advanced suffered...more

Hogan Lovells

Streamlined BCR approval: Understanding the EDPB's updated procedure

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On 19 March 2025, the European Data Protection Board published an updated procedure for co-operation between EU data protection supervisory authorities approving GDPR Binding Corporate Rules for intra-group transfers of EU...more

Alston & Bird

European Commission Moves to Extend Free Flows of Personal Data to the UK

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On March 18, 2025, the European Commission proposed to extend its adequacy decision in favor of the United Kingdom (‘UK’) for an additional six-month period. This would allow free flows of personal data from the EU to the UK...more

Latham & Watkins LLP

Kingdom of Saudi Arabia Issues New Data Transfer Risk Assessment Guidelines

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The guidelines specify the requirements for data controllers to conduct risk assessments related to the transfer or disclosure of personal data outside the Kingdom. ...more

Jenner & Block

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

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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

A&O Shearman

ICO publishes third edition of its Annual Tech Horizons Report

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On February 20 2025, the Information Commissioner’s Officer (the ICO) published the third edition of the Tech Horizons Report (the Report). The Report identifies four new technologies expected to emerge over the next 2 to 7...more

Katten Muchin Rosenman LLP

Tax Transparency and Data Privacy — Which Wins?

As tax authorities embrace new digital technologies, the issue of safeguarding citizens' data privacy rights steps to the fore. Since the implementation of the EU General Data Protection Regulation (GDPR) in 2018, there has...more

A&O Shearman

High Court rules on standard of consent required for profiling and direct marketing

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On January 23, 2025, Mrs Justice Collins Rice of the UK High Court issued a ruling in the case of RTM v Bonne Terre Limited and Hestview Limited (trading as Sky Betting and Gaming, (SBG)). The claim - The judgment...more

Cooley LLP

ICO Releases ‘Consent or Pay’ Guidance

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What happened? The UK Information Commissioner’s Office (ICO) has released updated guidance on ‘consent or pay’ business models. These models present users with a choice to either consent to the processing of their...more

A&O Shearman

ICO releases guidance on processing employment records

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On February 5 2025, the UK Information Commissioner's Office (ICO) released new guidance designed to help employers understand and comply with their obligations under the UK GDPR and the Data Protection Act 2018 in relation...more

DLA Piper

UK: Gambling Operator Held Liable for Breaching Data Protection Law

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In RTM v Bonne Terre Limited Hestview Limited, the English High Court found the Defendants, operating as Sky Bet (SBG), liable for breaches of data protection law. The claim raises important points of law for all...more

BCLP

Court of Appeal Considers the Test for CPR 19.8 Representative Actions in Prismall v Google

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The Court of Appeal has handed down its judgment in the case of Prismall v Google UK Ltd and DeepMind Technologies Ltd [2024] EWCA Civ 1516. Finding for Google, the Court of Appeal upheld the lower Court’s decision to...more

Fox Rothschild LLP

Valid Consent: General Public vs. Gamblers

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A new decision by the United Kingdom’s high court says that even if you have cookie and marketing consent mechanisms that are sufficient for valid consent under privacy laws for the general public, they may not be enough for...more

Littler

What to Expect from the UK’s New Data (Use and Access) Bill

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The new Data (Use and Access) Bill is making its way through the parliamentary process, and is expected to be passed in the first half of 2025. The Bill proposes to amend the UK data privacy regime to make it easier for...more

A&O Shearman

Data protection guidance for firms sharing customer information for the prevention of fraud

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The UK Information Commissioner’s Office (the ICO) has published guidance to help firms take steps to protect customers’ personal information when data is shared between firms to prevent fraud and scams....more

BCLP

Out With the Old and In With the New - The Data (Use and Access) Bill

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On 23 October 2024, the Data (Use and Access) Bill (the “DUAB”) was introduced to Parliament. The DUAB is the Labour government’s answer to the perceived shortfalls of the since-abandoned Data Protection and Digital...more

A&O Shearman

English Court reviews the ICOs first GDPR fine (again)

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In December 2019, the UK Information Commissioner’s Office (ICO) imposed a fine of £275,000 on Doorstep Dispensaree Limited (DDL) for multiple contraventions of the GDPR. On December 9 2024, five years on and three judgments...more

A&O Shearman

English judgment shines light on ICO investigation into Cambridge Analytica

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On March 23 2018, the Information Commissioner’s Office (ICO) executed a warrant to enter and search the offices of Cambridge Analytica. The purpose of the search was to access records concerning its alleged use of personal...more

A&O Shearman

English court determines the “meaning” of personal data

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In a previous blog post we considered an unsuccessful application to strike out a claim for alleged breaches of the UK GDPR, on the grounds that the claim was – in substance – a defamation claim. That application was...more

A&O Shearman

Securing our world: how businesses can prepare for and recover from cyber attacks

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As part of our Cybersecurity Awareness Month program of events, we hosted our inaugural Cybersecurity Forum on October 1 at our London office and online. Compèred by Ffion Flockhart, global head of cybersecurity, the day’s...more

Latham & Watkins LLP

EDPB Issues Guidelines on Processing Personal Data for Legitimate Interests Purposes

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

A&O Shearman

UK ICO makes recommendations on AI in recruitment

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On 6 November 2024, the Information Commissioner’s Office (ICO) published a report on the use of artificial intelligence (AI) in recruitment (the Report) following a series of consensual audits with developers and providers...more

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