The Information Commissioner’s Office, the U.K.’s data protection authority, has published guidance for data controllers on their data protection compliance obligations during the COVID-19 pandemic. The take-away point is that the ICO will take into account “the compelling public interest in the current health emergency” and will take a “reasonable and pragmatic” approach to enforcing data protection obligations. In light of this Guidance, the question of what particular steps are proportionate, in terms of General Data Protection Regulation compliance, will be of increasing importance while organizations and individuals navigate the pandemic.
