The UK has been steadily reworking its inherited GDPR, raising the question of how far it can diverge without risking EU adequacy. This hub covers that reform and ICO enforcement.

UK Data Protection

How the ICO Calculates a UK GDPR Fine: The Five Steps in Its Data Protection Fining Guidance

September 14, 2026

The Information Commissioner's Office published its Data Protection Fining Guidance on 18 March 2024 under section 160 of the Data Protection Act 2018. It explains when the regulator issues a penalty notice and how it reaches an amount, from a seriousness band through a turnover adjustment to a final check against the statutory cap. Both are set out here.

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UK Data Protection

The Data (Use and Access) Act 2025 Arrived in Eight Instalments — and Two Sections Have Still Not Arrived

September 7, 2026

The Data (Use and Access) Act 2025 is a nine-part statute covering smart data schemes, digital identity, buried pipes, birth registers, data protection, a new regulator and much else. Its commencement is the part most easily got wrong: Royal Assent brought almost none of it into force, and a reader working from the Act alone cannot tell what is law today.

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Cross-Border Transfers

The EU-US Data Privacy Framework: Adequacy Status After Latombe

September 1, 2026

The adequacy decision underpinning EU-US data transfers has been through one court challenge and one periodic review. This post states the status of Implementing Decision 2023/1795 by its own terms, describes the redress mechanism it relies on, and takes the posture of the legal challenge from the General Court's judgment and the notice of appeal rather than from commentary.

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UK Data Protection

The UK GDPR Is the EU Text With Words Swapped Out, and Then Rewritten

August 24, 2026

The UK did not write a data protection regulation of its own. It kept the EU text, substituted "the United Kingdom" for "the Union", and has been editing the result ever since. This guide covers the substitutions made in 2020, the rewrites the Data (Use and Access) Act 2025 made to Articles 6, 8A, 22 and 25, the "not materially lower" transfer test, and what the ICO has actually fined.

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