On 15 April, the UK Information Commissioner’s Office published guidance on their proposed approach to enforcement in light of the public health emergency. The guidance falls into four parts:
- The ICO’s high level principles that will inform their approach to enforcement (such as taking firm action against those looking to exploit the public health emergency, through nuisance calls or misuse of personal information);
- The ICO’s commitments to undertake certain actions (such as to resolve complaints without contacting an organisation or give it longer than usual to respond or rectify breaches, in certain circumstances);
- Specific guidance, to sit alongside the Regulatory Action Policy, as to the ICO’s approach to regulatory investigations and enforcement action during the public health crisis (which we explore in more detail below);
- The ICO’s approach to dealing with requests made under the Freedom of Information Act 2000 (FOI) and Environmental Information Regulations 2004 (EIR) to public authorities at this time.
