Tag Archives: ICO

ICO not compliant with post-Schrems II data protection law?

In which I finally receive a reply to my complaint about ICO’s Facebook page.

The issue of the transfer of personal data to the US has been the subject of much debate and much litigation. In 2015 the Court of Justice of the European Union (CJEU) struck down one of the then key legal mechanisms (“Safe Harbor”) for doing so. And in 2020 the CJEU did so with its successor, “Privacy Shield”. Both cases were initiated by complaints by lawyer and activist Max Schrems, and focused on the transfer of data from the EU to the US by Facebook.

Put simply, European data protection law, in the form of the GDPR and (as we must now talk about the UK in separate terms) UK data protection law, in the form of UKGDPR, outlaw the transfer of personal data to the US (or any other third country), unless the level of protection the data would receive in the EU, or the UK, is “not undermined” (see Chapter V of and recital 101 of GDPR/UKGDPR).

In “Schrems II” – the 2020 case – the CJEU not only struck down Privacy Shield – it effectively also laid down rules which needed to be followed if the alternative mechanisms, for instance using “standard contractual clauses” were to be used for transfers of personal data. Following the judgment, the European Data Protection Board (EDPB) issued guidance in the form of FAQs, which recommended an “assessment, taking into account the circumstances of the transfers, and supplementary measures you could put in place”. The EDPB guidance was subsequently endorsed by the UK’s own Information Commissioner’s Office (ICO)

The EDPB has recommended that you must conduct a risk assessment as to whether SCCs provide enough protection within the local legal framework, whether the transfer is to the US or elsewhere

What struck me as odd in all this is that the ICO themselves have a Facebook page. Given that Facebook’s own data governance arrangements involve the transfer of EU and UK users’ data to the US, and given that ICO don’t just operate their page as a newsletter, but actively encourage users to comment and interact on their page, it seemed to me that ICO were enabling the transfer of personal data by Facebook to the US. But even further than that, another CJEU judgment has previously made clear that operators of corporate Facebook pages may well function as a controller under the GDPR/UKGDPR, where they set parameters on the page. The Wirtschaftsakademie case held that – in the case of someone operating a “fan page”

While the mere fact of making use of a social network such as Facebook does not make a Facebook user a controller jointly responsible for the processing of personal data by that network, it must be stated, on the other hand, that the administrator of a fan page hosted on Facebook, by creating such a page, gives Facebook the opportunity to place cookies on the computer or other device of a person visiting its fan page, whether or not that person has a Facebook account.

By extension, it seemed to me, the ICO were in this position with their page.

So I put the point to them. After four months, and some chasing, I received a reply which not only confirmed my understanding that they are, and accept that they are, a controller, but that, nearly a year on from the Schrems II decision, they have not finished reviewing their position and have not updated their privacy notice to reflect their controller status in respect of their Facebook processing. (They also say that their legal basis for processing is “Article 6 (1) (e) of UK GDPR, public task” because “as a regulator we have a responsibility to promote good practice and engage with the public at large about data protection issues via commonly used platforms”, but I’d observe that they fail to give any attention to the proportionality test that reliance on this condition requires, and fail to point to the justification in domestic law, as required by Article 6.)

What the ICO response doesn’t do is actually respond to me as a data subject in respect of my complaint nor explain how they are complying with the international data transfer provisions of Chapter V of the GDPR/UKGDPR, and whether they have conducted any sort of transfer impact assessment (one presumes not).

As I said in my original complaint to ICO, I am aware that I might be seen as being mischievous, and I’m also aware I might be seen as having walked ICO into a trap. Maybe I am, and maybe I have, but there’s also a very serious point to be made. The cost to UK business of the Schrems II decision has been enormous, in terms of the legal advice sought, the internal governance reviews and risk assessments undertaken, and the negotiating or novation of contracts. At the same time the business and legal uncertainty is significant, with many wondering about their exposure to legal claims but also (and especially) to regulatory enforcement. If, though, the regulator is not complying with the relevant law, ten months on from the judgment (and five months on from my raising it with them as a concern) then what are controllers meant to do? And where do they turn to for guidance on the regulatory approach?

THE ICO RESPONSE

Firstly, it may be helpful to explain that following the findings of the CJEU in Wirtschaftsakademie, we started a review of the transparency information we provide to visitors of the page. The review was delayed when Schrems11 decision was issued as we needed to consider the impact of the judgement on any transfer element to the US.

We agree that as the Facebook page administrator, we are processing personal data of the visitors of our page and therefore we are controllers for this information. We process the names of the users as they appear on their Facebook profiles and any personal data they may share through their comments on our posts or via messages to us. We process this information in reliance on Article 6 (1) (e) of UK GDPR, public task. We consider that, as a regulator we have a responsibility to promote good practice and engage with the public at large about data protection issues via commonly used platforms.

For the cookies and similar technologies, Facebook is responsible for setting the cookies, when you visit our Facebook page.

We also receive anonymous information from Facebook in the form of aggregate statistics of all those who visit our page, regardless of whether they have a Facebook account or not. In line with the findings of the CJEU in Wirtschaftsakademie we are joint controllers with Facebook for this information. We process this information under Article 6 (1) (e) as well. The Insights include information on page viewings, likes, sharing of posts, age range, the device used and how it was accessed and breakdown of demographics. All Insights are received from Facebook by the ICO in aggregate format. Our PN will updated shortly to reflect the above information.

Like other regulators, the ICO is currently reviewing its position on international transfers following the judgment in Schrems II. As part of that review, it will, amongst other things, consider the questions that you have raised about the ICO’s use of Facebook. The ICO intends to publish its guidance on how UK organisations should address the question of international transfers, in due course, and will act in accordance with its guidance. That work is still in progress, and it will be published in due course.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Filed under adequacy, data sharing, EDPB, facebook, GDPR, Information Commissioner, international transfers, privacy notice, privacy shield, safe harbor, Schrems II, UK GDPR

ICO statutory duty to promote economic growth

From time to time I can be a bit critical of the Information Commissioner’s Office (ICO). Indeed, in the past I may have criticised them for appearing to promote things or exercise their functions in a way that exceeded what their core role is. For instance, I may have queried why they frequently appear to be cheer-leading for innovation and digital economic expansion (not that I think those things are inherently to be avoided).

But it’s important to note that their functions are not limited to regulation of specific laws. Rather, under section 108 of the Deregulation Act 2015, and (made under that Act) The Economic Growth (Regulatory Functions) Order 2017, the ICO, as well as a host of other regulators, has a statutory duty to exercise her regulatory functions (other than those under FOIA, interestingly) with regard to the desirability of promoting economic growth. In particular, she has to consider the importance for the promotion of economic growth of exercising the regulatory function in a way which ensures that regulatory action is taken only when it is needed, and any action taken is proportionate.

Additionally, under section 110 of the Deregulation Act 2015 ICO (and other regulators) must also have regard to this guidance: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/603743/growth-duty-statutory-guidance.pdf

When people (again, I should include myself) question, for instance, the paucity in the UK of low-level GDPR fines for low-level infringements, they should take into account these provisions.

Whether this aspect of the Deregulation Act 2015 is actually reconcilable with the provisions of the GDPR (and, now, the UK GDPR) is a separate question. In principle, there need not be a clash between the promotion of economic growth and the regulation of compliance with the duty to observe the fundamental right to protection of personal data, but in practice, such clashes tend to occur.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Dashcams and domestic purposes

What do people use dashcams and cameras on cycle helmets for? I’m sure that some (especially in the latter group) use them to capture footage of interesting journeys they have made. But a considerable proportion of users – surely – use them in the event that the user is involved in a road traffic incident. Indeed the “National Dash Cam Safety Portal”, although provided by a commercial organisation selling cameras, is operated in partnership with, and enables upload of footage to, police forces in England and Wales, and its FAQ clearly inform people of the evidential nature and implications of such footage. And a recent piece on the “Honest John” website suggests that one in four dashcam submissions result in a prosecution. Whatever the intentions were of the people who used those dashcams to record that footage, it is undeniable that the outcome of the processing of personal data involved had a significant effect on the rights of those whose data was processed.

Article 2 of the UK GDPR says that the law’s scope does not extend to processing of personal data “by a natural person in the course of a purely personal or household activity”, and the case law of the Court of Justice of the European Union (at least insofar as such case law decided before 1 January 2021 is retained domestic law – unless departed from by the Court of Appeal or the Supreme Court) makes clear that use of recording cameras which capture footage containing personal data outwith the orbit of one’s property cannot claim this “purely personal or household activity” exemption (see, in particular the Ryneš case).

Yet the position taken by the authorities in the UK (primarily by the Information Commissioner’s Office (ICO)) largely fails to address the difficult issues arising. Because if the use of dashcams and helmet cams, when they result in the processing of personal data which is not exempt under under the “purely personal and household exemption, is subject to data protection law, then those operating them are, in principle at least, obliged to comply with all the relevant provisions of the UK GDPR, including: compliance with the Article 5 principles; providing Article 13 notices to data subjects; complying with data subject request for access, erasure, etc. (under Articles 15, 17).

But the ICO, whose CCTV guidance deals well with the issues to the extent that domestic CCTV is in issue, implies that use of dashcams etc, except in a work context, is not subject to the UK GDPR. For instance, its FAQs on registering as a data protection fee payer say “the use of the dashcam in or on your vehicle for work purposes will not be considered as ‘domestic’ and therefore not exempt from data protection laws”. It is very difficult to reconcile the ICO’s position here with the case law as exemplified in Ryneš.

And what raises interesting questions for me is the evidential status of this dashcam and helmet cam footage, when used in prosecutions. Although English law has traditionally tended to take the approach that evidence should be admitted where it is relevant, rather than excluding it on the grounds that it has been improperly obtained (the latter being a species of the US “fruit of the poisoned tree” doctrine), it is surely better for a court not to be faced with a situation where evidence may have been obtained in circumstances involving illegality.

If this was a passing issue, perhaps there would not need to be too much concern. However, it is clear that use of mobile video recording devices (and use of footage in criminal, and indeed civil, proceedings) is increasing and will continue to do so, at the same time as access to such devices, and the possibility for their covert or surreptitious use, also increases. It is, no doubt, a tremendously tricky area to regulate, or event to contemplate regulating, but that is no reason for the ICO to duck the issue.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Filed under CCTV, crime, Data Protection, Information Commissioner, police

Start the DSAR countdown (but how?)

A while ago I wrote a piece on the Mishcon de Reya website pointing out that the Information Commissioner’s Office (ICO) had silently changed its guidance on how to calculate the “one month” timescale for responding to a subject access request under the General Data Protection Regulation (or “GDPR” – which is now domestic law in the form of the amended retained version of the GDPR, aka “UK GDPR”).

The nub of that piece was that the ICO (following the legal precedents) was now saying that “You should calculate the time limit from the day you receive the request“. Which was a change from the previous position that “You should calculate the time limit from the day after you receive the request “.

I have noticed, however, that, although the ICO website, in its UK GDPR guidance, maintains that the clock starts from the date of receipt, the guidance on “Law Enforcement Processing” (which relates to processing of personal data by competent authorities for law enforcement purposes under part 3 of the Data Protection Act 2018 (DPA), which implemented the Law Enforcement Directive) states that the time should be calculated

from the first day after the request was received

It’s not inconceivable (in fact I am given to understand it is relatively common) that a some controllers might receive a subject access request (or other data subject request) which must be dealt with under both the UK GDPR and the Law Enforcement Processing provisions (police forces are a good example of this). The ICO’s position means that the controller must calculate the response time as starting, on the one hand, on the date of receipt, and, on the other hand, on the day after the date of receipt.

And if all of this sounds a bit silly, and inconsequential, I would argue that it is certainly the former, but not necessarily the latter: failure to comply within a statutory timescale is a breach of a statutory duty, and therefore actionable, at least in principle. If the ICO really does believe that the timescale works differently under different legal schemes, then how, for instance can it properly determine (as it must, when required to) under Articles 57(1)(f) and 77(1) of the UK GDPR, or section 51(2) of the DPA, whether there has been a statutory infringement?

Statutory infringements are, after all, potentially actionable (in this instance either with regulatory action or private action by data subjects) – the ICO maintains a database of complaint cases and publishes some of this (albeit almost two years in arrears), and also uses (or may use) it to identify trends. If ICO finds that a controller has made a statutory infringement, that is a finding of potential significance: if that same finding is based on an unclear, and internally contradictory, interpretation of a key aspect of the law, then it is unlikely to be fair, and unlikely to be lawful.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Filed under Data Protection, Data Protection Act 2018, GDPR, Information Commissioner, subject access, UK GDPR, Uncategorized

GDPR’s scope – does it extend to China?

The answer to the question in the title is, of course, “yes”, if the processing in question is of personal data of data subjects in the EU, by a controller outside the EU, and related to the monitoring of data subjects’ behaviour as far as their behaviour takes place within the Union.

So, the activities of Zhenhua Data, in compiling its Overseas Key Individual Database, as described in The Mail, will be squarely within the scope of Article 3(2) of the General Data Protection Regulation (GDPR):

Boris Johnson and the Queen are among 40,000 Britons listed on a database compiled by a Chinese tech firm with reported links to Beijing’s military and intelligence networks, it can be disclosed.

Files on senior British politicians including the Prime Minister, members of the Royal Family, UK military officers and their families, and religious leaders are currently being stored by Zhenhua Data, a technology company based in Shenzhen, China as part of a ‘global mass surveillance system on an unprecedented scale’.

It seems difficult to imagine that the processing can possibly comply with GDPR. Where is the Article 14 notice? What is the Article 6 legal basis? Or the Article 9 exception to the general prohibition on processing special categories of data? Or the Article 30 record of processing activities? Or…or…or…?

But here’s the problem with any legislative attempt to extend the scope of laws beyond geographical and jurisdictional borders, to the activities of those who are not consulted, nor assigned rights, nor (in all likelihood) bothered: how does one enforce those laws? In 2018 (oh those heady early GDPR days!) the Information Commissioner’s Office (ICO) was reported to have told the Washington Post that its practice of only allowing those who paid for its premium subscription to refuse tracking cookies was unlawful. How many figs the WaPo gave is evidenced by a glance at its current subscription model:

(i.e. it appears to have changed nothing.)

Indeed, as the ICO said at the time

We hope that the Washington Post will heed our advice, but if they choose not to, there is nothing more we can do in relation to this matter

If there was nothing ICO could do against a newspaper outside the jurisdiction, consider how unrealistic is the idea that it might enforce against a Chinese company rumoured to work for the Chinese military, and which is said to view its mission as ‘using big data for the “great rejuvenation of the Chinese nation”‘.

The logical question, though, which arises is this – in the absence of an effective regulatory scheme to enforce them what exactly is the point of GDPR’s (or even more trenchantly, the UK GDPR’s) extra-territorial scope provisions?

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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If ICO won’t regulate the law, it must reboot itself

The exercise of the right of (subject) access under Article 15 of the General Data Protection Regulation (GDPR) is the exercise of a fundamental right to be aware of and verify the lawfulness of the processing of personal data about oneself.

That this is a fundamental right is emphasised by the range of enforcement powers available to the Information Commissioner’s Office (ICO), against those controllers who fail to comply with their obligations in response to an access request. These include the power to serve administrative fines to a maximum amount of €20m, but, more prosaically, the power to order the controller to comply with the data subject’s requests to exercise his or her rights. This, surely, is a basic function of the ICO – the sort of regulatory action which underlines its existence. This, much more than operating regulatory sandboxes, or publishing normative policy papers, is surely what the ICO is fundamentally there to do.

Yet read this, a letter shown to me recently which was sent by ICO to someone complaining about the handling of an access request:

 

Dear [data subject],

Further to my recent correspondence, I write regarding the way in which [a London Borough] (The Council) has handled your subject access request.

I have contacted the Council and from the evidence they have provided to me, as stated before, it appears that they have infringed your right to access under the GDPR by failing to comply with your SAR request. However, it does not appear as though they are willing to provide you with any further information and we have informed them of our dissatisfaction with this situation.

It is a requirement under the Data protection Act 2018 that we investigate cases to the ‘extent appropriate’ and after lengthy correspondence with the Council, it appears they are no longer willing co-operate with us to provide this information. Therefore, you may have better results if you seek independent legal advice regarding the matters raised in this particular case.

Here we have the ICO telling a data subject that it will not take action against a public authority data controller which has infringed her rights by failing to comply with an access request. Instead, the requester must seek her own legal advice (almost inevitably at her own significant cost).

Other controllers might look at this and wonder whether they should bother complying with the law, if no sanction arises for failing to do so. And other data subjects might look at it and wonder what is the point in exercising their rights, if the regulator will not enforce them.

This is the most stark single example in a collection of increasing evidence that the ICO is failing to perform its basic tasks of regulation and enforcement.

It is just one data subject, exercising her right. But it is a right which underpins data protection law: if you don’t know and can’t find out what information an organisation has about you, then your ability to exercise other rights is stopped short.

The ICO should reboot itself. It should, before and above all else, perform its first statutory duty – to monitor and enforce the application of the GDPR.

I don’t understand why it does not want to do so.

[P.S. I think the situation described here is different, although of the same species, to situations where ICO finds likely non-compliance but declines to take punitive action – such as a monetary penalty. Here, there is a simple corrective regulatory power available – an enforcement notice (essentially a “steps order”) under section 148 Data Protection Act 2018.]

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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ICO – fines, what fines?

No surprise…but ICO has only issued four notices of intent to serve a fine since GDPR came into application (and one fine)

I made a quick Freedom of Information Act (FOIA) request a few weeks ago to the Information Commissioner’s Office (ICO), asking

since 25 May 2018
1) how many notices of intent have been given under paragraph 2(1) of schedule 16 to the Data Protection Act 2018?
2) How many notices of intent given under 1) have not resulted in a monetary penalty notice being given (after the period of 6 months specified in paragraph 2(2) of the same schedule to same Act)?

I have now received (4 September) received a response, which says that four notices of intent only have been issued in that time. Three of those are well known: one was in respect of Doorstep Dispensaree (who have since received an actual fine – the only one issued under GDPR – of £275,000); two are in respect of British Airways and of Marriott Inc., which have become long-running, uncompleted sagas; the identity of the recipient of the final one is not known at the time of writing.

The contrast with some other European data protection authorities is stark: in Spain, around 120 fines have been issued in the same time; in Italy, 26; in Germany (which has separate authorities for its individual regions), 26 also.

Once again, questions must be asked about whether the aim of the legislator, in passing GDPR, to homogenise data protection law across the EU, has been anywhere near achieved.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Filed under Data Protection, Data Protection Act 2018, GDPR, Information Commissioner, monetary penalty notice

Met – FOI requester’s focus on police misconduct was a “vexatiousness” factor

I regularly criticise the Information Commissioner’s Office on this blog. But credit where it’s due. They have upheld a complaint about the Met Police’s handling of a Freedom of Information Act 2000 (FOIA) request, in which the Met, remarkably, had argued that the request for information about police officers stopping people without cause and asking for their ID was vexatious (per section 14(1) of FOIA).

Clearly, there was some history to the request and the requester, and in line with authority, the Met were entitled to take this into account at arriving at their (now overturned) decision. But, as the decision notice points out, one of the factors which they said pointed towards vexatiousness was this:

Complainant’s focus upon police misconduct and/or related issues

I’ll say that again

Complainant’s focus upon police misconduct and/or related issues

Yes, the Met did indeed argue that a focus by a FOIA requester on police misconduct was a factor which led them to believe there was a pattern of behaviour which made this request (about stopping people without cause and asking for their ID) vexatious.

So well done ICO for dismissing that argument.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Complaining

When A-Levels results were announced last week, the Information Commissioner’s Office (ICO) advised those unhappy with the processing of their personal data to

raise those concerns with the exam boards first, then report to us if they are not satisfied

And in its “service standards” the ICO even says

we expect you to give the organisation the opportunity to consider it first. In order for us to look at their information rights practices we need you to provide us with their reply [emphasis added]

and

Our role is not to investigate or adjudicate on every individual complaint. We are not an ombudsman.

(This last bit is, I would submit, correct – the ICO is not an ombudsman according to my understanding of such a role (under which an ombudsman has powers to investigate complaints, but only to make recommendations as a result, rather than legally enforceable orders). How this squares with Elizabeth Denham’s confident pronouncement in the foreword to the ICO’s Regulatory Action Policy that she is “both an educator and an ombudsman”, I’ve never quite grasped, but, in her support, the ICO is a member of the Ombudsman Association. What a muddle.)

As I mentioned a few days ago, the ICO does not have the power simply to refuse to investigate a complaint by a data subject – it must, under Article 77 of GDPR, handle complaints and investigate them “to the extent appropriate”. I can see that in normal cases, it might be beneficial, and provide a complete picture, for there to have been correspondence between the data subject and the controller, but in some other cases, it hardly seems helpful, let alone a legal requirement, to raise a complaint with a controller first. So data subjects do not have to complain to exam boards first. (Please note – I’m not encouraging, or wishing for, a flood of complaints to be made to ICO, but, equally, if data subjects have specific complaint rights under GDPR, we (and I include the ICO in “we”) can’t just pretend they don’t exist.)

So, if data subjects were to complain to (and hold their ground with) ICO, what would happen next? How long does an investigation take?

As to the last question, oddly, it is difficult to know. In recent months, I have asked ICO on a few occasions through their chat service how long data protection complaints are taking merely to be allocated to a caseworker. I have regularly been told that cases are taking around three months to be allocated (a Freedom of Information request by someone else from June last year got the same figure). However, the ICO’s annual report, published only a few weeks ago says, at page 50, “we unfortunately have not been able to meet our target of 80% of [data protection] cases being resolved within 12 weeks” but they have achieved 74% being resolved within 12 weeks. I may be missing something, but how can 74% of data protection cases have been resolved within 12 weeks, when 100% of them are not allocated to a caseworker until 12 weeks have passed? The only way I can square these figures is if caseworkers “resolve” 74% of cases effectively on the day they get them. If that is the case, it might raise questions of the amount of rigour in the investigation process.

In any case, it seems clear that if an aggrieved student wished to complain about the processing of her personal data during the awarding of A-Levels this year, she would a) (probably wrongly) be expected by ICO first to complain to the exam body, then wait to receive a response, before b) then complaining to the ICO, and waiting three months for her complaint to be allocated to a caseworker. At that point, she might have her complaint investigated in line with Article 77 of GDPR. If the best a student this year might expect would be that her complaint might get allocated to a caseworker by December, more than three months after the distressing debacle which was the awards process, would the ICO realistically be said to be complying with its Article 57(1)(f) task to investigate complaints “within a reasonable period”?

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Cometh the hour…

One thing in particular struck me about the statement from the Information Commissioner’s Office (ICO) in response to the huge distress and uncertainty facing thousands of students and their families, following the announcement of A-level grades:

Anyone with any concerns about how their data has been handled should raise those concerns with the exam boards first, then report to us if they are not satisfied

In some ways, this is standard. Even the ICO’s “contact us” page leads a potential complainant through various stages before telling people who haven’t raised their concerns by “contacting the [offending] organisation in writing” to “Raise your concern with the organisation handling your information”.

Whilst I can understand the reason for this general approach (ICO’s resources are limited, and many complaints can no doubt be resolved at source), it is difficult to reconcile it with what the law requires the ICO to do. Article 77 GDPR says that a supervisory authority must handle complaints lodged by a data subject, and investigate, to the extent appropriate, the subject matter of the complaint. There is no caveat, no exemption. It does leave the option open for the ICO to handle a complaint, and choose not to investigate it all, but that is not what the ICO is doing here (and in its general approach).

But it must be said that sometimes, as it is permitted to, under Articles 57 and 58, the ICO does conduct investigations of its volition. It also has a range of powers, including the power to give an opinion to parliament and/or the government. Given that its Norwegian counterpart has indicated it will take strong action against the International Baccalaureate Organisation, I am hopeful that, as a new week of uncertainty for students approaches, the ICO will take this particular bit between its teeth, and properly investigate such a pressing issue.

The views in this post (and indeed most posts on this blog) are my personal ones, and do not represent the views of any organisation I am involved with.

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Filed under Data Protection, fairness, GDPR, Information Commissioner, parliament