ICO and reprimands – unfair to recipients?

I’ve written on the Mishcon de Reya website about the Information Commissioner’s Office’s use of reprimands for data protection infringements, despite the absence of any published guidance or procedure. Coupled with the lack of any way of appealing a reprimand, does this risk putting recipients in an unfair position?

https://www.mishcon.com/news/icos-regulatory-use-of-reprimands-does-it-need-a-rethink