TikTok’s misuse of children’s data results in £12.7 million ICO fine

The UK’s Information Commissioner’s Office (“ICO“) has fined Tik Tok Information Technologies UK Limited and TikTok Inc (“TikTok“) £12.7 million for breaching the UK GDPR, in particular for failing to protect children’s privacy. The ICO had previously issued a notice of intent to fine TikTok £27 million for various data protection law breaches between May … Read more

Transfer Impact Assessments – divergence between EDPB and ICO approaches

Now that the deadlines have passed for implementing: EU Standard Contractual Clauses (“EU SCCs”) into all new and existing contractual arrangements involving restricted transfers of data under the EU GDPR; and the UK equivalent to the EU SCCs (the UK specific International Data Transfer Agreement (“IDTA“) or the EU SCCs in combination with the UK … Read more

President Biden’s Executive Order implements EU-US data privacy framework

President Biden recently issued an Executive Order on Enhancing Safeguards for United States Signals Intelligence Activities (the Privacy EO) outlining steps that the US Government is taking to implement the US commitments under the European Union-US Data Privacy Framework (the Privacy Framework) that the US and the European Commission (EC) announced in March 2022 to … Read more


Following the UK Government’s publication of its response to the DCMS consultation on the Data Reform Bill last month (see our blog post on this here), the UK Government has published and introduced to Parliament a 192-page draft text which now has a new name: the Data Protection and Digital Information Bill. The new bill … Read more


Summary Following the European Commission’s (“EC”) announcement of the new Trans-Atlantic Data Privacy Framework (the “Framework”) earlier this year, Lawyer and privacy activist Max Schrems’ organisation, NOYB, recently issued an open letter to EU and US officials arguing that the proposed framework is unlikely to withstand legal challenge and overly resembles its predecessor, the now-defunct … Read more

Fair Use of AI in Financial Services – A new White Paper with UK Finance

Recent years have seen growing scrutiny of the use of artificial intelligence (AI) in financial services and a greater awareness of the potential of these technologies. It is no surprise that questions of AI fairness and bias are increasingly front of mind. Existing law is not keeping up with the rise and speed of new technology. With UK Finance, we have published a white paper, as a contribution to the debate on how to apply ethical principles in practice to the benefit of firms and customers. Our use of practical scenarios has helped refine our understanding of the fair use of AI and the practical challenges of building a high-level ethical framework. Read more