ICO sets out three year strategic plan

July 14, 2022

The ICO has set out its new strategic plan, “ICO25”. The three year plan sets out the ICO’s regulatory approach and priorities. It points out that the UK government intends to make changes to the UK data protection regime midway through the life of the plan. This includes the intention to introduce a new constitutional governance model for the ICO.

The ICO25 plan sets out how the ICO will regulate and prioritise work over the next three years. The accompanying action plan setting out the focus for the year ahead includes details of work focused on empowering people, including:

  • looking at the impact of predatory marketing calls;
  • looking at the use of algorithms within the benefits system;
  • considering the impact the use AI in recruitment could be having on neurodiverse people or ethnic minorities, who were not part of the testing for such software; and
  • ongoing support of children’s privacy.

The plan also emphasises the importance of certainty and flexibility for business, announcing a package of actions with the aim of helping save businesses at least £100 million across the next three years. To achieve this the ICO will:

  • publish internal data protection and freedom of information training materials;
  • create a database of ICO advice provided to organisations and the public;
  • produce a range of templates to help organisations develop their own approaches;
  • create an ICO moderated platform for organisations to discuss and debate compliance and share information and advice;
  • develop a range of ‘data essentials’ training, specifically aimed at SMEs whose involvement with data protection is a by-product of their core activity; and
  • set up iAdvice, an advice service to offer early support for innovators.

The report sets out support for the public sector, including a revised approach to public sector fines. In practice, this will mean an increased use of the ICO’s wider powers, including warnings, reprimands and enforcement notices, with fines only issued in the most serious cases. It also proposes the creation of a cross Whitehall Senior Leadership Group to drive compliance and high standards of information across government departments.

The report also includes the ICO’s commitment to supporting the development of modern freedom of information, including prioritising FOI complaints and a greater emphasis on dispute resolution around complaints. The ICO is consulting on the draft plan until 22 September,