UK publishes framework for responding to significant personal data breaches

The Cabinet Office has published a Model Action Plan (MAP) to establish a consistent, coordinated, and robust framework for all government departments and arm's-length bodies responding to significant personal data breaches.

The plan prioritises the well-being, personal safety, privacy, and legal rights of affected individuals while introducing mandatory central reporting that will enable the government to analyse incident trends, share mitigation measures, and address systemic weaknesses. Significant data breaches under the MAP framework include incidents that meet the statutory reporting threshold to the Information Commissioner's Office (ICO), as well as those that expose a large number of data subjects or high-profile individuals to serious harm. It also covers incidents that pose national security risks, such as exposing the UK to espionage or disrupting critical national infrastructure, and breaches originating from third-party suppliers that affect multiple organisations.

The policy notes that due to the sensitivity of government-held data, these breaches can cause severe physical, financial, and emotional harm to individuals, alongside severe organisational impacts, financial penalties, and broader risks to the UK.

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