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UK: ICO launches public consultation on draft ICO25 strategic plan

The Information Commissioner's Office ('ICO') launched, on 14 July 2022, a public consultation on its draft strategic plan for the coming three years, titled ICO25, which also includes its Annual Action Plan for October 2022 to October 2023. In particular, ICO25 details a vision of the ICO in the coming period and of the ICO's approach, and lays out a set of priorities, focusing on safeguarding the rights of the most vulnerable persons. More specifically, in the speech launching ICO25, John Edwards, Information Commissioner, explained that practical changes will take place within the ICO and set out a package of actions to reduce the cost of compliance through investing in a series of services, tools, and initiatives to enable organisations to benefit from the ICO's advice and experience. For instance, ICO25 notes that the ICO will, among other things:

  • publish its internal data protection and freedom of information training materials;
  • create a database of all the advice it has provided to organisations and to the public;
  • produce a range of templates to help organisations develop their own approaches to working in compliance with applicable law;
  • develop a range of data essentials training, specifically aimed at small-and-medium sized enterprises;
  • provide binding rulings to declare its position on a business practice or question of law in advance;
  • create more sector-specific work and guidance; and
  • revise the ICO's approach to public sector fines, having determined that public money is best used to support the delivery of essential services.

In light of this, the Annual Action Plan for 2022-2023, located within Annex One of ICO25, states that the ICO will focus on areas over the coming 12 months which include:

  • the impact of predatory marketing calls;
  • the use of algorithms within the benefits system;
  • the impact of the use of AI in recruitment for neurodiverse persons or ethnic minorities, who were not part of testing for the software; and
  • support of children's privacy.

Furthermore, Edwards recalled that the proposed reforms to data protection law in the UK will permit further changes, noting that the ICO will have greater control over resource allocation.

Comments may be submitted via an online survey until 22 September 2022.

You can read the speech here, the press release here, the consultation page here, and ICO25 here.