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David Erdos @daviderdos.bsky.social · 30/09/2026

On day ICO becomes the Information Commission, I'm please to publish 📢 a new article exploring the its enforcement (or lack thereof) of (UK) #GDPR & both #scrutiny & #oversight of this since 2028/19: www.sciencedirect.com/science/arti... Fines have averaged just 6.8 and final notices 1.8/year.

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David Erdos @daviderdos.bsky.social · 30/07/2026

The HoC Defence Committee has contradicted the Information Commissioner's understanding that MoD #Afghan UK #GDPR #databreach was "a one-off occurrence following a failure to following [sic] usual checks", with MoD itself even admitting it occured "while officials were following agreed procedures"

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David Erdos @daviderdos.bsky.social · 14/07/2026

1. Consistent with their lack of orientation towards a collective public (or society), the Court of Justice of the EU (CJEU) correctly indicated that databases like Lexbase did not fall within #GDPR Article 85’s concept of #journalism 2/6

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David Erdos @daviderdos.bsky.social · 13/04/2026

New Article! In 1960 #Ireland enjoyed a strong, even if informal, external association with the Commonwealth in 1960 but by 1979 all significant #citizenship, #tariff, #monetary & #diplomatic arrangements were at an end: www.tandfonline.com/doi/full/10.... (also www.slideshare.net/slideshow/ir...)

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David Erdos @daviderdos.bsky.social · 01/04/2026

In 5yrs since it left EU #dataprotection framework & then enacted Data (Use & Access) Act (DUAA), the UK has shifted to a more business friendly approach. But largely through solidifing a limited enforcement stance as substantive #GDPR change is rather limited papers.ssrn.com/sol3/papers....

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David Erdos @daviderdos.bsky.social · 31/03/2026

On back of MPs letter about #TattleLife the UK ICO said it was investigating. But how can it regulate #onlineabuse when it failed to update its policy guidance for #GDPR despite saying it would do so for +5 yrs, then deleted this & now says it holds no info? More at inforrm.org/2026/03/31/e...

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David Erdos @daviderdos.bsky.social · 19/03/2026

Although currently misfiled in the Information Commissioner's Office database as an enforcement notice, the ICO's £14.5M UK #GDPR fine against Reddit regarding an alleged failure of #agegating is now out: ico.org.uk/action-weve-... 1/2

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David Erdos @daviderdos.bsky.social · 23/02/2026

“Regulating #AI in a Changing World: #Oversight & #Enforcement”: Great to see video of Info Law & Policy Centre 2025 Conference keynote panel online. My talk focused on UK #dataprotection situation compared to #EU #GDPR experiences in #Italy & #Germany: lnkd.in/eNEeUEyW Summary notes below.

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David Erdos @daviderdos.bsky.social · 19/02/2026

With over 40K #dataprotection complaints but just 2 fines totalling only £3.8m and no UK #GDPR enforcement notices in 2024/25, where has scrutiny and oversight of the ICO been? Pleased to post new working paper on this, also exploring avenues for positive intervention papers.ssrn.com/sol3/papers....

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David Erdos @daviderdos.bsky.social · 17/02/2026

The ICO's new policy to just "record" many UK #GDPR complaints is at serious odds with a @phsombudsman.bsky.social ruling from 11/2025 which held complainants had a right to "an assessment under section 165 of the DPA as to whether it is likely or unlikely that the processing" was lawful. 1/3

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David Erdos @daviderdos.bsky.social · 10/02/2026

Here's my new open-access article providing first comprehensive #law & #policy analysis of #Commonwealth #citizenship from end of WW2 to the present, also looking at its proposed future as a mechanism to faciliate short-term esp. #business mobility: www.tandfonline.com/doi/full/10....

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David Erdos @daviderdos.bsky.social · 09/02/2026

This is despite obvious correlation between rising complaints & recent degrading of enforcement & also clear fact that if ICO refuses even to investigate then enforcement is categorically being refused without any controller undertaking whatsoever being received.

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David Erdos @daviderdos.bsky.social · 09/02/2026

The ICO additionally maintains that cost considerations (significantly the result of its own decision to channel resources away from its core investigatory tasks) can justify a lack of prompt handling even of “high-harm cases”, despite this being explicitly rejected in Delo.

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David Erdos @daviderdos.bsky.social · 05/02/2026

Lovely to see hard copy of new book on the #dataprotection & #humanitarian action & proud to have contributed chapter exploring role of the #unitednations guidelines from 1990 in shaping regulation here. It's all open access so please do check it out! www.taylorfrancis.com/books/oa-edi...

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David Erdos @daviderdos.bsky.social · 13/01/2026

Following many egregious Government #dataprotection breaches over the past few years it's v disappointing to see ICO-Government MoU doubles-down on the ICO's flawed "public sector approach" which "priortises enagement" rather than corrective powers use: ico.org.uk/media2/m15nb...

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David Erdos @daviderdos.bsky.social · 14/11/2025

Alongside grave individual impact, Public Accounts Committee finds that Afghan #spreadsheet #databreach will likely cost c£850m & arose within a context where the MoD "did not do enough to learn the lessons from previous data breaches" reported to ICO committees.parliament.uk/committee/12...

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David Erdos @daviderdos.bsky.social · 30/10/2025

Beyond #Afghan #databreach, the UK ICO faces increased scrutiny due to need to renew #dataprotection #adequacy. The European DP Board is urging much greater scrutiny of the robustness of its complaints handling & effectiveness of UK #GDPR sanctions and remedies: www.edpb.europa.eu/system/files...

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David Erdos @daviderdos.bsky.social · 29/10/2025

The ICO claim #UKGDPR complaints are arising "as people become more aware of their #dataprotection rights" & now propose to refuse investigation of many of these. In fact, complaints have been stable since #GDPR & but with ↓↓ regulatory action by ICO have ↑ since 2023: inforrm.org/2025/10/28/c...

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David Erdos @daviderdos.bsky.social · 08/09/2025

In midst of #Gaza horror &⬆️Recognition of #Palestine by Members (up to 80% by end Sept & 🤞more soon) it's good to see Stuart Mole, former Head of it's Secretary-General's Office, call for Palestine #Commonwealth membership pathway (paused since 1997) www.commonwealthroundtable.co.uk/general/poli...

An aerial view showing destruction in Rafah after Israeli forces withdrawal Source: UNRWA

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David Erdos @daviderdos.bsky.social · 01/09/2025

Invoking "economic growth" & the vaguest of claims about #AdTech the UK Information Commissioner plans to explicitly “enable” non-compliant business models. Even partial Responses (by 7 Sept 25) pushing back on this erosion of rights & democratic processes would be good! ico.org.uk/about-the-ic...

Annotated extract from ICO AdTech consultation

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David Erdos @daviderdos.bsky.social · 01/09/2025

Invoking "economic growth" & the vaguest of claims about #AdTech the UK Information Commissioner plans to explicitly “enable” non-complaint business models. Even partial Responses (by 7 Sept 25) pushing back on this erosion of rights & democratic processes encouraged. ico.org.uk/about-the-ic...

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David Erdos @daviderdos.bsky.social · 30/07/2025

New Working Paper: Pleased to post first comprehensive historical and comparative #law & #policy analysis of #Commonwealth #citizenship from end of WWII to present, also looking at its possible future faciliating short-term mobility especially for #business purposes: papers.ssrn.com/sol3/papers....

Infographic summary of history and trajectory of Commonwealth citizenship from end of Second World War to the present

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David Erdos @daviderdos.bsky.social · 25/07/2025

Good to see coverage of ICO's UK #GDPR & #ePrivacy track-record including (slightly sensationalised) analysis of decisionmarketing.co.uk/top-story/la... of my blog piece ukconstitutionallaw.org/2025/07/22/d... Momentum is building for parliamentary scrutiny: committees.parliament.uk/publications...

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David Erdos @daviderdos.bsky.social · 23/07/2025

Even before inaction on 2022 #Afghan UK #GDPR #databreach, which put many lives at ↑ risk, civil society groups like @openrightsgroup.bsky.social were saying that those who have experienced #dataprotection violations were more likely to win lottery than get meaningful redress from ICO.

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David Erdos @daviderdos.bsky.social · 23/07/2025

The ICO's failure to enforce UK #GDPR is at odds not just with #EU comparators like #Germany, #Spain & #Italy but with UK #regulation protecting people. Eg #dataprotection complaints are c. 70% those of #food hygiene yet formal action is at c. 0.3% level. See ukconstitutionallaw.org/2025/07/22/d...

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David Erdos @daviderdos.bsky.social · 22/07/2025

My new blog exploring Information Commissioner's 2024/25 Annual Report shows that inaction on 2022 #Afghan UK #GDPR #databreach was sadly in line with poor & starkly declining track-record in formal monitoring & enforcement of UK #dataprotection & #ePrivacy: ukconstitutionallaw.org/2025/07/22/d...

ICO data protection enforcement statistics 2024/25 alongside regulatory comparisons and legal standards

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David Erdos @daviderdos.bsky.social · 19/07/2025

First look at @iconews stance on MoD #databreach, which put up to 100K #Afghans at grave risk, incl. its relationship to other MoD UK #GDPR violations, the lack of any formal ICO investigation, regulatory action or even reprimand & the need for action now: inforrm.org/2025/07/19/t...

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David Erdos @daviderdos.bsky.social · 16/07/2025

In 2023 the UK Information Commissioner stated that it was "necessary" "to apply the full sanctions" where UK #GDPR breaches "put people's lives at risk" x.com/ICOnews/stat... But today no regulatory action (DPA 2018 s160) results from #databreach that placed +18K at risk & perhaps caused death

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David Erdos @daviderdos.bsky.social · 04/06/2025

Surprised Information Commissioner's Office claims track-record of “stand[ing] up during scandals” as with Leveson Inquiry: vimeo.com/1070964964. In fact, Leveson held ICO’s #dataprotection conduct constituted “regulatory failure” arising from it “not be[ing] keen to exercise" powers & functions 1/3

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David Erdos @daviderdos.bsky.social · 02/06/2025

Pleased to post new paper on "ends" of #Irish strong albeit informal post-WWII external association with #Commonwealth during 1960s & 70s. This demise alongside continued #UK-Irish arrangements can tell us much about #UK, #Ireland, #Europe & Commonwealth history: papers.ssrn.com/sol3/papers.... 1/4

Combined image of old and modern Commonwealth symbols, UK and Irish flags

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David Erdos @daviderdos.bsky.social · 02/06/2025

Pleased to publish this new Modern Law Review article on how the Retained EU Law (Revocation & Reform) Act removes UK #GDPR legal priority & how its Regulations 2013/1417 narrow meaning of "fundamental" #humanrights in UK #dataprotection to #ECHR alone: onlinelibrary.wiley.com/doi/10.1111/... 1/4

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