ICO updates its special category data guidance, releases two online tools

Published: 29/10/2026
| ICO

The Information Commission (ICO) has updated its regulatory guidance on handling special category data under Article 9 of the UK General Data Protection Regulation (GDPR) to reflect legislative changes introduced by the Data (Use and Access) Act 2025 (DUAA).

Recognising that organisations often struggle to identify the right legal bases for processing sensitive personal data, the ICO has released two new interactive online tools that clarify what organisations must, should, and could do to comply.

The first interactive tool aims to support organisations in navigating the Article 9 conditions governing special category data processing and identify which legal justifications apply to their operations. 

The second tool guides organisations through the substantial public interest conditions and helps determine whether any specific exemptions apply to their processing activities.


Training announcement: Freevacy provides comprehensive training for new and existing practitioners on the changes introduced by the DUA Act to the UK General Data Protection Regulation (GDPR), the Data Protection Act 2018 (DPA18), and the Privacy and Electronic Communications Regulations 2003 (PEC-Regulations). Our courses are always up to date and provide a forum for learning and discussing how to ensure your data protection processes remain compliant. Find out more.

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