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ICO reveals how it will enforce data protection legislation

Court ruling

The ICO has published guidance revealing how it will enforce data protection legislation.

The guidance, which explains the ICO’s powers, when it will use them and how it calculates fines, contains a “nine-step mechanism” for calculating fines, which is:

  1. Assessment of seriousness
  2. Assessment of degree of culpability
  3. Determination of turnover
  4. Calculation of an appropriate starting point
  5. Consideration of relevant aggravating and mitigating features
  6. Consideration of financial means
  7. Assessment of financial means
  8. Assessment of economic impact
  9. Assessment of effectiveness, proportionality, dissuasiveness
  10. Early payment reduction


The ICO has created a matrix to calculate the appropriate starting point for fines, in addition to which there will still be case-specific assessment of aggravating and mitigating factors to apply after that.

In addition, the ICO has included in this guidance how, when calculating a fine, it must consider the desirability of promoting economic growth. This may be a nod to the damage caused to the economy by COVID-19.

If your organisation is looking to comply with the requirements of the GDPR then take a look at how our CSaaS and DPaaS solutions can help.

Appointing NormCyber as our virtual DPO has given Ferrero the best of both worlds – access to data protection experts who understand what we stand for as a business, without the hefty overheads usually associated with appointing an in-house DPO.

Harpreet Thandi
Regional Counsel, UK & Ireland, Ferrero

We were looking for a virtual DPO service that offered all of the benefits of a fully qualified data protection lawyer, without the overheads of an in-house hire. The DPaaS solution from norm. has been invaluable in helping us to ensure we respect the integrity of our customers’ personal information, while using it to continue to deliver differentiated products and services which support our growing customer base.

Mike Whitfield, Compliance Manager

CSaaS allows me to step away from multi-vendor management as the Security Operations Centre coordinates all of the technology for me.

David Vincent, CTO

We were in the market for an independent Data Protection Officer service that was well versed with both UK and EU regulators. We’re thrilled to have acquired this service knowing that an expert is available 24/7.

Suzanne McCabe, Head of Project Management
James Hambro & Partners

Norm’s penetration testing layer, along with the suite of CSaaS modules has enabled MA to exceed all its audit requirements for its major clients.

Rob Elisha, ICT and CRM Manager
Montreal Associates

The speed of your Data Protection Officer’s response was very impressive – it was far quicker than I would have expected even from an in-house DPO

Will Blake, Director of Technology and Analytics
CRU Group