ILN Data Privacy Paper

United Kingdom 2.2. Additional or ancillary regulation, directives, or norms 2.2.1. The Data Protection (Charges and Information) Regulations 2018 require all UK data controllers to register and pay a fee to the ICO. 2.2.2. The ICO has issued a number of statutory Codes of Practice, which are relevant for assessing compliance with UK GDPR. These codes include: 2.2.2.1. Data Sharing Code of Practice: A statutory code that provides practical guidance for organisations on sharing personal data in a way that complies with data protection law, aiming to give confidence to share data fairly and proportionately. 2.2.2.2. Age Appropriate Design Code of Practice: Aims to ensure that online services appropriately safeguard children's personal data by setting out standards for data protection and privacy by design. 2.2.2.3. Employment Practices Code: Provides guidance for employers on how to handle personal information about their employees in a way that respects their privacy while meeting the legitimate needs of the business. 2.2.2.4. Data Protection and Journalism Code Of Practice: Provides guidance for organisations that process personal data for journalism. 2.2.3. Sector ‑ specific regimes influence privacy obligations in practice, including financial services expectations (FCA/PRA), health and NHS information governance, employment law, and cybersecurity frameworks.

2.2.4. The National Cyber Security Centre provides widely adopted security guidance. 2.2.5. For international transfers of personal data, the UK has the International Data Transfer Agreement (“IDTA”) and the UK Addendum to the EU Standard Contractual Clauses (“SCCs”), together with transfer risk assessment expectations. 2.3. Upcoming or proposed legislation 2.3.1. The Data (Use and Access) Act 2025 was passed in 2025 and is being implemented in stages. This Act amends UK GDPR, DPA 2018, and PECR, with measures intended to streamline documentation and accountability, adjust cookies/consent expectations, and clarify uses of legitimate interests.

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