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ICO updates its regulatory approach in response to coronavirus

Court ruling

ICO updates its regulatory approach in response to the coronavirus pandemic.

The ICO first published a document setting out its regulatory approach during the coronavirus pandemic in April 2020. This was updated in in July and again now.

The ICO has updated its regulatory approach to explain how it will regulate in the coming months “with the caveats and exceptions that reflect today’s reality”. The ICO makes clear that it will adjust its regulatory approach to take into consideration the difficulties organisations face trying to operate during these uncertain and challenging times, emphasising its self-described role as “a pragmatic and proportionate regulator”.

In introducing this updated approach the Information Commissioner has published an open letter that says, “we will always have a role in bringing to task those organisations that wilfully ignore the rules, or fail to take responsibility for their actions. That has not changed, nor has the legal requirement that we consider the operational and financial pressures an organisation is facing before we intervene”.


The ICO regards itself as being in a difficult position between, on the one hand, having a duty to enforce the GDPR, and on the other hand, recognising that very many organisations are struggling to function properly, let alone comply with the ‘rules’. This is especially acute in the hospitality sector, where organisations are now legally required to obtain contact details of customers, (when before this collection was only encouraged by UK government guidance).

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.

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Regional Counsel, UK & Ireland, Ferrero

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CRU Group