ORG responds to the ICO's draft DP enforcement procedural guidance consultation

23/01/2026 | Open Rights Group

The Open Rights Group (ORG) has submitted a detailed response to the Information Commissioner's Office (ICO) consultation on the process it follows when conducting investigations and taking enforcement action under the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA18).

In its 19-page response, the ORG addresses questions ranging from the mechanisms that the ICO uses to resolve cases outside of opening a formal investigation, how the ICO determines whether to open an investigation and its approach to conducting investigations, through to its application of warnings, reprimands, enforcement notices and its process for settlement discussions and concluding cases.


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