Lessons Learned: Bank of Ireland UK faces ICO reprimand for Data Breach


On December 15, 2023, the Information Commissioner’s Office (ICO) issued a reprimand to Bank of Ireland UK following a significant data breach. The ICO found that the bank had sent incorrect outstanding balances on 3,284 customers’ loan accounts to credit reference agencies. The repercussions of such errors in the financial sector can be severe, affecting individuals’ creditworthiness and potentially hindering their access to essential financial products. This blog delves into the details of the incident, the implications for affected customers, and the measures recommended by the ICO to ensure future compliance with data protection laws.

The Data Breach:

The ICO investigation revealed that Bank of Ireland UK was in breach of data protection law for failing to ensure the accuracy of personal data, as outlined in article 5(1)(d) of the General Data Protection Regulation (GDPR). The inaccurate information sent to credit reference agencies could have had a detrimental impact on affected customers, influencing lenders’ decisions regarding approvals for mortgages, credit cards, or loans.

Impact on Customers:

Due to the complex nature of credit scoring and the multitude of factors involved, it was deemed impossible to precisely determine the actual damage caused to each customer. However, the ICO concluded that it was reasonable to assume that the inaccurate data would have had a negative impact. Customers might have faced unfair refusals for credit or been granted excessive credit on products they could potentially struggle to afford.

The ICO’s Response:

The ICO’s Head of Investigations emphasised the far-reaching consequences of mistakes made by financial institutions on people’s everyday lives. The potential ramifications for affected customers included being refused mortgages, loans, or credit cards, as well as facing difficulties in obtaining mobile phone contracts, insurance policies, or signing up with utility companies. The ICO acknowledged the steps taken by Bank of Ireland UK to rectify the error, support affected customers, and review its data-management processes.

Reprimand and Recommendations:

In response to the breach, the ICO issued a reprimand to Bank of Ireland UK. The recommended steps to ensure compliance with data protection laws include:

  1. Continued Customer Support: Bank of Ireland UK is urged to continue supporting affected customers, acknowledging the potential hardships they might face due to the inaccurate data.
  2. Robust Processes: The ICO recommends the implementation of robust processes to prevent future data breaches. Regular reviews of these processes are essential to identify and rectify any weaknesses.
  3. Knowledge Sharing: To prevent a recurrence of similar issues, the ICO emphasises the importance of sharing learnings across the organisation. This involves disseminating insights gained from the incident to relevant departments, promoting a culture of data protection and awareness.


The reprimand from the ICO serves as a reminder of the profound impact that data breaches in the financial sector can have on individuals’ lives. While mistakes happen, the key lies in the proactive measures taken to rectify errors, support affected parties, and prevent future occurrences. As technology continues to play a central role in the financial industry, maintaining the highest standards of data protection is not just a legal obligation but a fundamental commitment to the well-being of customers.

If you wish to speak to a Data Protection Officer, and benefit from a complimentary 30-minute consultation, please contact info@normcyber.com