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Discover the comprehensive range of data protection services at Data Protection People. Tailored to meet the unique needs of your organisation, our expert team has successfully handled every challenge imaginable. Whether you’re navigating compliance complexities or enhancing data security, trust DPP to be your partner in safeguarding information.

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A data protection officer doesn't have to be a full time employee and in many respects it's better to have a company like DPP take on the role. Watch the video below to find out more about our outsourced DPO and privacy officer services or reach out and get in touch with us.

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Data Protection People's world-class GDPR Support Desk. If you're navigating the complex landscape of data protection, PCI DSS, and cybersecurity, our support desk is your reliable compass.

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A range of high level reviews, detailed audits and mid-range assessments to test compliance with data protection laws and standards

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Explore our Subject Access Request (SAR) Handling Service and understand how Data Protection People can support your organisation

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At Data Protection People, our cyber security services are designed to fortify your digital defences. With a proven track record spanning diverse sectors in the UK, our seasoned team brings a wealth of experience in handling a wide array of cybersecurity challenges. Reach out to us and explore how DPP can enhance your organisation’s cyber resilience.

PCI DSS Compliance Services for Merchants

A PCI assessment is an audit for validating compliance with the Payment Card Industry Data Security Standard (PCI DSS), a set of security standards for merchants who accept, process, store or transmit credit card information.

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A PCI assessment is an audit for validating compliance with the Payment Card Industry Data Security Standard (PCI DSS), a set of security standards for merchants who accept, process, store or transmit credit card information.

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Supporting DPOs

Flexible Support When You Need It

At Data Protection People, we recognise the dynamic challenges and unique responsibilities of the Data Protection Officer (DPO) role. Beyond offering standard support, we provide a comprehensive suite of services crafted to empower DPOs at every step.

Collaborative Community: Navigating the intricate landscape of data protection can be isolating. That’s why we’ve fostered a collaborative community of privacy professionals. As a DPO with us, you’re never alone. Our network serves as a forum for insightful discussions, sharing solutions, and building a sense of camaraderie.

Expert Guidance and Advice: The journey of a DPO is often filled with complex decisions. Our seasoned team of experts is your reliable resource, offering timely advice and strategic guidance. We’re not just a service provider; we’re your dedicated partners in overcoming challenges and making informed decisions.

Advanced Training for Continuous Growth: Stay ahead in your role with our advanced training programs. Tailored for DPOs, our courses delve into intricate aspects of data protection, providing you with a competitive edge. It’s not just about meeting the present challenges but ensuring your continuous growth and excellence in your role.

Audits, Assessments, and Document Reviews: Our services extend beyond conventional boundaries. From comprehensive audits and assessments to meticulous document reviews, we ensure that your data protection strategies are not only compliant but also optimised for efficiency.

Simplifying Complexity for Future Ease: Beyond addressing current challenges, our mission is to simplify the complexities inherent in data protection. By partnering with Data Protection People, you’re not just solving problems – you’re ensuring a smoother, more efficient role in the future. We streamline processes, making your responsibilities more manageable and your decisions more impactful.

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Access to a Team of Industry Experts

At Data Protection People, our expertise spans across diverse sectors, ensuring that businesses of all sizes and orientations receive tailored Data Protection and Cyber Security solutions. From the dynamic commercial sector and agile SMEs to the impactful third sector and expansive multi-nationals, we extend our services to fortify the digital defences of every business entity.

Commercial Sector

Elevate your data protection and cybersecurity standards in the bustling landscape of the Commercial Sector. We offer tailored solutions designed to safeguard your sensitive information, ensuring compliance and resilience against evolving threats. Partner with us to fortify your digital assets and foster a secure environment for sustained growth.

SMEs

Small and Medium Enterprises (SMEs) form the backbone of innovation. Our data protection and cybersecurity services are crafted to match the agility of SMEs. Navigate the digital landscape securely, optimize your operations, and scale confidently with our tailored solutions that prioritize your unique business needs.

Third Sector

Third Sector

For organisations in the Third Sector driven by purpose, our data protection and cybersecurity expertise align with your mission. Safeguard sensitive data, build stakeholder trust, and amplify your positive impact. Let our solutions be the backbone of your technology infrastructure, ensuring that your focus remains on making a difference.

Multi Nationals

For the global footprint of Multi Nationals, our data protection and cybersecurity services provide a comprehensive shield. Navigate the complexities of international regulations with confidence. From compliance strategies to threat intelligence, we've got your data security needs covered, empowering your multinational endeavors with resilience.

Public Sector

In the Public Sector, trust and accountability are paramount. Our data protection and cybersecurity consultancy ensures that your operations align seamlessly with regulatory requirements. From confidential citizen data to streamlined governance, our solutions empower public entities to serve with integrity and technological excellence.

Why Use Our Outsourced DPO Services?

Save Time, Money and Guarantee Compliance

Navigating the intricate landscape of data protection demands more than just a DPO — it requires a dedicated team committed to excellence. Our Outsourced DPO Services extend beyond the traditional role, offering a comprehensive approach to legal compliance and pragmatic solutions.

Why Choose Outsourcing?

An outsourced DPO brings a wealth of experience, not just in the law but also in crafting workable solutions. Their impartiality is fortified by a team of privacy practitioners, ensuring that your organization benefits from a spectrum of expertise. Should the need arise, seamless coverage during absences is guaranteed, eliminating the vulnerability associated with a single in-house DPO.

Staying Headache-Free

Concerned about the disruption if your DPO moves on? With an outsourced model, transitions are smooth, and you won’t experience the sudden headache of a critical role vacancy. The continuity provided by a team ensures that your data protection responsibilities are seamlessly handled.

Compliance Tailored to You

Our Outsourced DPO Services align seamlessly with your legal obligations, whether you’re mandated to appoint a DPO or choose to do so voluntarily. We understand that compliance is not just about ticking boxes but about ensuring a robust, practical approach to data protection. Choose Data Protection People for a worry-free, compliance-driven outsourced DPO solution — because your data protection journey should be as smooth as it is secure.

“I cant recommend Data Protection People enough, they have helped me in so many different areas, no matter how complex the challenge or how large the obstacle, DPP always has the answer.

I can call the team at any time and have built an amazing relationship with them, in times of frustration they are here to calm me down and create a plan, they are a pleasure to work with.”

Mark Leete
Eastlight Community Homes

Data Protection People Blogs & Podcasts

Data Privacy Learning & Guidance

Data Protection People have the UK’s #1 Data Protection Podcast with over 150 episodes available across all audio streaming platforms, we also post regular content designed to simplify complex areas of data protection and cyber security, check out some of the podcasts and articles below and make data protection easy today.

Exploring Signatures as Biometrics

When Your “John Hancock” Becomes Sensitive Data: Exploring Signatures as Biometrics

Ever looked at your signature and thought, “It’s just a fancy way I write my name”? Think again. In our increasingly digital world, that casual scribble at the bottom of forms is gaining new significance, particularly in places like Jamaica, where the Jamaican Data Protection Act (JDPA) now classifies signatures as sensitive biometric data, putting them in the same category as fingerprints and DNA.

This classification isn’t just fancy legal talk, it’s recognising that your signature has unique behavioural patterns that only you make.

What Makes Your Signature Biometric Data?

Under Jamaica’s Data Protection Act, biometric data is defined as “any information relating to the physical, physiological or behavioural characteristics of an individual, which allows for the unique identification of the individual.” But what exactly makes a signature biometric?

Consider what happens when you sign your name:

  • Your hand moves in patterns nobody else can perfectly replicate
  • You apply distinctive pressure with your pen
  • Your personal hand-eye coordination manifests in each stroke
  • Your signature even reveals subtle hints about your personality and current mood

The way you make loops in your letters, the special touches you add, and how fast you move the pen on the paper. These things are just as unique to you as your face or fingerprints.

In today’s digital landscape, e-signatures take this biometric data collection even further:

  • They capture exactly how quickly you move the stylus
  • They note when you pause (even for milliseconds)
  • They measure precisely how much pressure you’re applying
  • They record the exact timing between each stroke

The Dual Nature of Signatures

Signatures occupy a unique position in the spectrum of biometric identifiers:

  1. A traditional form of verification – Signatures have been used for centuries as a means of authentication, predating modern digital identification methods
  2. A behavioural biometric – Each signature contains distinctive characteristics including pressure points, speed, stroke order, and style that can be analysed to verify identity.

This duality creates an interesting challenge. People easily give signatures without concern, unlike fingerprints or facial scans, which raise privacy worries. However, the JDPA classifies signatures as “sensitive personal data,” meaning they need extra protection.

Take a moment to count how many times you’ve signed something in the last month alone:

  • Credit card receipts
  • Package delivery confirmations
  • Work documents
  • Medical intake forms

Each instance represents you handing over sensitive personal data without giving it a second thought!

Implications for Organisations

The classification of signatures as biometric data has several significant implications:

  1. Data Protection Officer Requirement: Organisations regularly collecting signatures may need to appoint a dedicated officer to oversee data protection compliance.
  2. Enhanced Security Measures: Signatures require stronger security measures than ordinary personal data, including appropriate technical and organisational safeguards.
  3. Explicit Consent Requirements: Organisations collecting signatures need proper consent mechanisms that specifically address the biometric nature of signature data.
  4. Records Management Challenges: Both physical and digital signatures must be properly stored, retained, and eventually disposed of with appropriate security measures.

Practical Steps Forward

Organisations processing signatures should consider taking these steps:

  1. Audit current signature collection practices
  2. Assess whether a Data Protection Officer appointment is necessary
  3. Review consent mechanisms to ensure they address the sensitive nature of signature data
  4. Implement appropriate security measures for both physical and digital signature storage
  5. Develop retention policies that limit unnecessary storage of signature data

Conclusion

Your signature is more than just a name. It is a piece of YOU. It is a biological data that reveals how your brain and body work together. It contains patterns as unique as a fingerprint. Yet, we share it freely without much thought. By classifying signatures as “sensitive personal data,” the JDPA highlights their role as unique personal identifiers. This recognition ensures they receive the protection they deserve.

Next time someone casually asks you to “sign here,” remember you’re not just confirming something, you’re handing over biometric data (a sensitive personal data) that’s increasingly protected by law around the world.

As businesses adjust to new regulations, they need to balance their practical needs with stronger data protection, keeping signatures both secure and easy to use.

With growing concerns about data privacy, it’s time we give our “John Hancock”, the protection they truly deserve.

 

Data Controller Vs Data Processor: The Key Differences

Organisations have varying degrees of responsibility when it comes to processing personal data. Depending on your involvement, you may be either a data controller, processor, joint controller or sub-processor. 

So, which category does your business fall into? In this article, we’ll cover the responsibilities of a data controller and processor, and determine which role applies to you. 

What Is a Data Controller?

A data controller is an individual or legal entity, such as a company or public authority, that makes decisions about how to process data. They have sole control and responsibility for the processing, including how personal data is collected, used, stored, altered and disclosed. 

As data controllers bear greater risk, they are subject to stricter compliance obligations. You can also be classified as a joint controller, whereby two or more controllers determine the purposes and means of processing. Essentially, joint controllers have the same or shared purpose for their processing activities. 

What Is Your Role as a Data Controller? 

Data controllers must comply with the UK GDPR for all processing activities, including any carried out by a third-party processor. 

You must: 

  • Comply with the seven data protection principles as outlined in Article 5 of the UK GDPR.
  • Allow data subjects (individuals) to exercise their individual rights, including the right to access (through subject access requests), erasure, rectification, objection and others. For more information, read our guidance on data subject rights
  • Implement technical and organisational security measures to protect personal data from unauthorised or unlawful processing, accidental loss, destruction or damage. 
  • Assess the measures your chosen data processor is taking to process data in compliance with the UK GDPR. 
  • Enter into contracts with your data processor which outline set requirements for them to follow. 
  • Notify the ICO and affected individuals of personal data breaches when required (if the violation is high risk to the individual’s rights and freedoms).
  • Fulfil your accountability obligations, such as completing data protection impact assessments (DPIAs) and appointing a data protection officer (DPO). (You may not require the latter – find out if you need a DPO in our blog.) 
  • Work alongside supervisory bodies to allow them to carry out their responsibilities.
  • Comply with the UK GDPR’s restrictions on personal data transfers outside the UK.
  • Pay your data protection fee, unless you are exempt. 

What Is a Data Processor? 

A data processor is an individual (external to the controller’s workforce) or legal body that processes personal data on the controller’s behalf. 

For example, an employer (the data controller) provides an employee’s salary and personal details to a payroll accountant. The accountant (processor) processes this data to generate payslips, acting on the employer’s instructions without deciding what data is collected or how it’s used. 

As such, a processor cannot act in their own interests. They can, however, subcontract some or all of the processing to another processor. Doing this makes you a sub-processor. 

What Is Your Role as a Data Processor? 

While data processors may have fewer responsibilities, they still must: 

  • Follow the data controller’s instructions about processing personal data (unless required by law).
  • Enter into a binding contract with the controller and follow the obligations it sets. 
  • Obtain consent from the data controller if you want to outsource the processing to another processor. 
  • Enter into a contract with the sub-processor (if applicable), which outlines terms and conditions similar to those in the contract between you and the controller.
  • Implement relevant technical and organisational measures to maintain the security of personal data. 
  • Notify the data controller of data breaches as soon as possible. You will also assist the controller with its responsibilities around data breaches.
  • Alert the controller if any of their instructions would cause a breach. 
  • Comply with certain accountability obligations, such as maintaining records and designating a DPO
  • Gain authorisation from the controller when transferring data outside the UK. (International transfers must also comply with the UK GDPR’s rules.) 
  • Cooperate with supervisory bodies. 

Why Knowing Your Role Is Essential

The GDPR obligations for a data controller and a data processor may overlap, but their roles are distinct. Data controllers hold more responsibility than a processor, as they have total control over the processing activities. This doesn’t mean, however, that processors can be negligent of their obligations. Both parties are just as accountable for their own compliance.  

If you’re a controller, you must ensure your processing activities uphold the UK GDPR; otherwise, you’re liable for non-compliance. Your responsibility also extends to your processors’ compliance. This means you’re obligated to assess and contractually bind any third parties on your behalf. Should a data breach occur on the processor’s behalf, you will also be held liable, unless you can prove otherwise. 

By knowing your part, you (the controller or processor) will be able to carry out everything expected of your role. This avoids any unnecessary fines, penalties and security risks that come from non-compliance. 

The data processor vs controller distinction isn’t clear-cut for every company, so it’s wise to speak to a GDPR consultancy before taking any other actions. 

Get Expert GDPR Support with Data Protection People

Confused about your responsibilities under the UK GDPR? We’ll help you understand your role, including the steps needed to achieve and maintain compliance. 

We offer flexible GDPR support, ranging from ad-hoc SARs support to fully outsourced DPO services. Want to find out how we can help? Speak to our team today, and we’ll be in touch.

Subject Access Request: How to deal with a SAR

Subject Access Requests: Prepare Now for the Summer Spike Amid Data Breach Fears 

Recent cyber incidents involving major UK retailers and service providers have reignited public concern about how personal information is stored and used. As data breaches dominate the headlines, individuals are becoming more proactive about protecting their privacy and one of the most powerful tools available to them is the Subject Access Request (SAR). 

At Data Protection People, we anticipate a significant increase in SARs over the coming months. When public trust is shaken, it’s common for people to ask questions like, “What information do you hold about me?” and “What are you doing with it?” For data protection teams, this means more scrutiny, tighter deadlines, and a greater need for internal coordination. 

If your organisation isn’t yet braced for this wave, now is the time. The Information Commissioner’s Office (ICO) expects timely responses, regardless of resource pressure. Here’s how to manage SARs effectively, even under increased demand and maintain compliance without compromise. 

What Is a Subject Access Request? 

A Subject Access Request (SAR) is a legal right that enables individuals to access information about how an organisation handles their personal data. This typically involves providing copies of the personal data held by the organisation, as well as details about the purpose of processing, the duration of data retention, and any third parties with whom the data may be shared. This right is granted under the UK General Data Protection Regulation (UK GDPR) , specifically Article 15 of the Regulation.. The purpose is to give people greater visibility and control over how their personal information is being collected, used, and shared. 

“Personal data” refers to any information that can identify an individual, either directly or indirectly. This could include names, addresses, contact details, email correspondence, CCTV footage, HR records, medical notes, or even recorded phone calls. Essentially, any data linked to an identifiable person. 

Organisations have a duty to recognise and act on these requests promptly, even if the request is informal. Failing to respond appropriately can lead to enforcement action by the Information Commissioner’s Office (ICO) and potentially damage the trust and reputation your organisation has worked hard to build. 

Responding to SARs effectively isn’t just about ticking a compliance box, it’s about respecting individuals’ rights and demonstrating your organisation’s commitment to data protection and transparency. 

 Step 1: Spot the Request Early 

The first step in successfully handling a Subject Access Request (SAR) is being able to identify one in the first place and it’s not always obvious. SARs don’t need to come with  legal language or follow a specific format. In fact, many individuals won’t use the words “Subject Access Request” at all. They may simply say something like, “Can I see the data you’ve got on me?” or “I want copies of all emails where I’m mentioned.” 

These types of requests can arrive in a wide range of ways, via email, contact forms, live chat, social media, phone calls, or even through face-to-face interactions. This means any employee, not just those in legal or compliance, could be the first point of contact. 

What organisations must do: 

  • Train all staff to recognise a SAR when they see one. 
  • Create a clear, internal escalation process so front-line teams know where to direct requests. 
  • Develop and share example scenarios in training materials to reinforce awareness. 

Top tip: Always log the exact date the request was received. This marks day one of your legal deadline, which is one calendar month to respond in full. 

Step 2: Confirm Identity 

Before you disclose any personal data, it’s essential to ensure that the requestor is who they say they are. If you have genuine doubts about their identity, you’re entitled to ask for additional information to verify it. 

However, this should always be reasonable and proportionate. For example, asking for a utility bill or photo ID might be acceptable in some contexts, but overly intrusive checks can be seen as obstructive and may breach data protection principles themselves. 

Key considerations: 

  • Tailor the request for ID based on the sensitivity of the data being requested. 
  • Don’t use ID verification as a way to delay the process. You should only pause the one-month clock if you genuinely cannot proceed without further confirmation. 
  • Ensure all ID documents received are handled securely and not retained longer than necessary. 

Step 3: Clarify the Request (When Needed) 

Not all SARs will be clear. Some may ask for “all the data you have on me,” which can span thousands of documents across multiple systems. In these cases, it’s acceptable and often helpful to ask the individual to clarify their request. This could involve: 

  • Specifying a date range 
  • Naming a particular department or employee 
  • Indicating the kind of interaction or context (e.g., job application, customer service complaint) 

However, it’s important to understand that you cannot refuse or delay processing the request purely because it’s broad. Start gathering what you can while awaiting clarification. 

Best practice: 

  • Keep any clarification requests polite, clear, and focused. 
  • Document all correspondence in case of future ICO review. 

Step 4: Search Thoroughly 

This is often the most time-consuming part of the SAR process. Identifying and locating all personal data related to the individual. This includes both digital and physical records, structured and unstructured data, and any data that directly or indirectly identifies the individual. 

Areas to check may include: 

  • CRM and HR systems 
  • Emails and email archives 
  • Shared drives and cloud storage 
  • Instant messaging tools (like Teams) 
  • Databases, forms, spreadsheets 
  • Paper files and filing cabinets 
  • CCTV footage (where facial recognition or identifying context is present) 

It’s easy to overlook less formal storage locations such as inbox folders or team-shared documents. Make sure your organisation has a comprehensive SAR search protocol to avoid missing key data. In order to make the search process as simple as possible organisations should document their common search areas and ensure that data is only stored within specified locations to allow for easy retrieval. 

Step 5: Review and Redact 

Once the relevant data has been gathered, it’s critical to review all of it carefully before disclosure. You are legally required to protect the rights and freedoms of others, which includes ensuring you don’t inadvertently release information that belongs to a third party. 

This is where redaction becomes essential. Any reference to other individuals (names, emails, opinions, etc.) may need to be removed or anonymised. 

In addition, certain exemptions under the Data Protection Act 2018 may apply. Common exemptions include: 

  • Legal privilege (e.g., communications with solicitors) 
  • Management information (e.g., confidential HR evaluations) 
  • Negotiations or legally confidential references 
  • Data processed for crime prevention or national security 

Tip: Document your decision-making process when applying exemptions or redactions, this can help protect your organisation if challenged. 

Step 6: Respond Within One Calendar Month 

Once you’ve reviewed and prepared the data, you must respond to the individual within one calendar month of receiving the request. If the request is particularly complex, involving multiple data sources or large volumes of information, you may extend the deadline by a further two months, but you must inform the individual of this within the original one-month window. 

Your response must include: 

  • A copy of the personal data, in an accessible, commonly used format (e.g., PDF or Word) 
  • Details of how you have undertaken the SAR (e.g. the search parameters and search terms used) 
  • Details of redactions and exemptions applied if any to ensure that individuals are aware of why redactions have been made.  
  • A reminder of the individuals right to complain to the ICO.  

Important note: The response should be clear and easy to understand. Avoid jargon and make the data as digestible as possible especially when responding to members of the public. 

Getting SAR Read: Practical Steps for Organisations 

With SAR volumes likely to rise this summer, preparation is key. Here’s how your organisation can get ahead: 

  1. Audit Your Data

Understand what personal data you hold, where it lives, and who is responsible for it. The more you know about your systems, the faster you can respond to a SAR. 

  1. Create or Refresh Your SAR Process

Have a clear, documented workflow in place that outlines roles, responsibilities, and timeframes. Automating parts of this process. Such as search and redaction, this can save valuable time. 

  1. Upskill Your Staff

Ensure staff across departments know how to spot a SAR and escalate it. Offer training or guidance to reduce the risk of delays or mismanagement. 

  1. Allocate Resources

Plan for peak periods by ensuring your data protection team isn’t stretched too thin. Consider temporary support or tools that can streamline response tasks. 

Why It Matters More Than Ever 

A well-handled SAR isn’t just a regulatory obligation, it’s a reflection of your organisation’s commitment to transparency and trust. In the wake of data breaches and public concern, timely and accurate responses help rebuild confidence and show that you take data protection seriously. 

Delays, missed deadlines, or incomplete responses won’t just frustrate individuals. They could trigger investigations or fines from the ICO. 

Need Help Managing SARs at Scale? 

As the UK’s number one data protection consultancy, Data Protection People supports organisations of all sizes in handling SARs quickly, securely, and lawfully. Whether you need a one-off audit or an end-to-end SAR handling solution, we’re here to help. 

Get in touch today — and stay one step ahead of the summer SAR surge. 

Can Age Checks and Curfews Really Protect Kids Online?

Will Proof-of-Age and Social Media Curfews Under the Online Safety Act Actually Work?

The UK’s Online Safety Act introduces one of the most comprehensive frameworks for regulating online content to date. Among its more debated proposals are two high-impact, child-focused measures: mandatory proof-of-age verification and a potential legally enforced social media curfew for under-18s. While the public discussion has largely centred on intent—protecting children from harm online—the critical issues lie in feasibility, privacy, and precedent.

As data protection and information security professionals, we believe these measures warrant deeper analysis, especially given the serious implications for data protection, user rights, and technical enforcement.

Proof of age

The Online Safety Act mandates that platforms hosting potentially harmful content accessible to children must take active measures to prevent underage access. While the Act doesn’t prescribe a single, uniform age verification method, it strongly encourages the use of age assurance mechanisms, particularly for high-risk content such as pornography, gambling, and social media features that could be addictive or algorithmically manipulative.

Under the Act, platforms are required to assess the potential risks to children using their services and ensure that children have access only to age-appropriate content. This includes enforcing age restrictions consistently across platforms, making it clear to users what measures are in place to protect children from harmful content. These age verification mechanisms may include:

  • ID-based verification (e.g., government-issued IDs or payment cards)
  • AI-driven age estimation (e.g., facial recognition)
  • Third-party age assurance tools (e.g., parental controls, third-party digital identity services)
  • Mobile network/SIM-based authentication

However, the Act does not mandate a specific method. Instead, platforms are expected to take a proportionate approach based on the nature of the content and the platform. They must also ensure that these age restrictions are enforced consistently and transparently, with clear communication of these measures in their terms of service.

Despite these flexible requirements, there are trade-offs with each method:

  • Biometric technologies (like facial recognition) raise concerns under UK GDPR, particularly around lawful basis for processing and data minimisation.
  • ID submissions (e.g., government-issued IDs) increase the risk of data breaches and identity theft, particularly when dealing with younger users who may not fully understand the risks involved.

Age verification frameworks have been trialled in Germany, where the Kommission für Jugendmedienschutz (KJM) began issuing enforcement orders in 2021 against adult content platforms that failed to implement robust age gates. These efforts, however, drew criticism from German privacy and civil rights groups such as Gesellschaft für Freiheitsrechte (GFF) and Chaos Computer Club, who warned that such systems eroded online anonymity and lacked transparency about data retention.

Similarly, in France, legislation passed in 2023 authorised ARCOM (Autorité de régulation de la communication audiovisuelle et numérique) to mandate age checks on adult sites. Non-compliance could result in site blocking. This sparked strong opposition from digital rights organisation La Quadrature du Net, which argued that the measures created an infrastructure for mass digital identification, with little oversight or clarity on data protection.

In both jurisdictions, concerns were raised that age verification—though well-intentioned—risked breaching Article 8 of the European Convention on Human Rights, which guarantees the right to privacy.

What about social media curfews?

The notion of a legally mandated curfew—preventing under-18s from accessing platforms like TikTok, Instagram, and Snapchat after 10pm—is now under active consideration by UK policymakers. Technology Secretary Peter Kyle recently acknowledged the potential to act in this space, referencing TikTok’s voluntary 10pm shutdown feature for under-16s as a possible model.

While the motivation is understandable—late-night usage has been linked to sleep disruption and increased vulnerability to online harms—the implementation is far from straightforward. A legally enforceable curfew would require platforms to:

  • Continuously monitor account activity
  • Link that activity to a verified age
  • Restrict access based on UK time zones and age brackets

This raises obvious questions about technical feasibility and proportionality. Any system that enables real-time age-based content restrictions risks intrusive tracking and surveillance of young users. It also presumes universal compliance by platforms and seamless integration across services—conditions that are not currently met.

Moreover, such curfews may prove ineffective in practice. Children and teenagers are often more digitally agile than policy anticipates. Workarounds like VPNs, secondary accounts, or logging in via devices registered to adults could easily circumvent restrictions. Worse still, excessive restrictions may push vulnerable users toward less regulated, offshore platforms where they are at greater risk.

Both Germany and France offer cautionary lessons. In each case, aggressive legislative attempts to introduce age verification have been hampered by having legal challenges from civil society groups, public backlash over data privacy and data protection and technical uncertainty about accuracy and coverage.

In Australia, the eSafety Commissioner has also trialled age assurance tools as part of a broader child safety initiative. However, rollout has been cautious, with a focus on balancing protection with privacy, and an acknowledgment that no single verification system can yet meet all the criteria of accuracy, inclusivity, security, and usability.

Even in the United States, where several states have passed age-appropriate design bills inspired by the UK’s earlier code, implementation has been slowed by constitutional challenges over free speech and privacy.

The UK is at a regulatory crossroads. The Online Safety Act presents an opportunity to improve digital protections for children. But that ambition must not be undermined by rushed implementation or headline-driven policy. For any age verification or curfew measure to be credible, it must:

  • Be technically feasible without disproportionate data collection
  • Meet UK GDPR and human rights standards on privacy and freedom of expression
  • Include transparent enforcement mechanisms and public accountability

Be part of a wider ecosystem that includes education, parental controls, and platform design changes. Without these safeguards, we risk enacting policies that are symbolic rather than effective and potentially damaging to privacy rights for all internet users.

The intention to protect children online is both right and necessary. But the tools we choose must not compromise the very principles we seek to uphold.

Written by Catarina Santos – Data Protection Expert

Managing Employee SARs

Managing Subject Access Requests from Employees & Ex-Employees

Data Protection Made Easy Podcast – Episode 114

Subject Access Requests (SARs) submitted by current or former employees are among the most sensitive and complex data protection challenges organisations face. In Episode 114 of the Data Protection Made Easy Podcast, we welcomed Nia Roberts from Woodgate & Clarke to share her insights alongside our regular hosts Philip Brining, Catarina Santos, and Caine Glancy.

If you’re involved in HR, legal, compliance, or data protection, this is an episode you won’t want to miss. SARs from staff can surface during contentious periods and often involve highly personal data, workplace grievances, and emotionally charged decisions.

Listen below or find us on Spotify, Apple Podcasts, and all major streaming platforms.

What We Covered

This session dives into some of the most frequently asked questions and overlooked risks when handling SARs from employees and ex-employees. The team explored:

🔹 Common Triggers and Misconceptions

From employment disputes and grievances to misunderstanding of rights, we discussed the motivations behind employee SARs and how these requests are sometimes unfairly perceived as “troublemaking.”

As Catarina Santos explained, it’s essential to reframe the narrative:

“The moment an employee submits a SAR, there’s often suspicion. But they’re simply exercising a right, and organisations need to avoid viewing this as a hostile act.”

🔹 SARs and Organisational Culture

The episode opened with a reflection on how important organisational attitude is when dealing with SARs internally. Do line managers panic? Do HR teams try to limit the scope unfairly? The cultural tone of how SARs are approached sets the standard for compliance, and respect for rights.

🔹 The Community Speaks

This episode was particularly lively, with dozens of listeners sharing personal experiences in the live chat, from management asking for redaction reviews to WhatsApp messages being considered disclosable.

Philip Brining highlighted the value of the community:

“We’re not here to preach, we’re here to learn from each other. Today’s discussion proved again how much experience exists across this community.”

🔹 Tools of the Trade: Teams, WhatsApp & Chat Platforms

Are your workplace chat tools covered by SARs? Very possibly. The group discussed how platforms like Microsoft Teams, Slack, and WhatsApp are increasingly scrutinised during employee SARs especially if conversations include personal data.

🔹 Balancing Access, Proportionality, and Security

SAR compliance doesn’t mean giving everything. As Caine Glancy pointed out, organisations must strike a balance between access and protection:

“It’s easy to get swept up in emotion, especially when the SAR involves current staff. But we need to remain impartial, proportional, and legally grounded.”

The team also touched on unfounded and excessive requests, case law, and the ICO’s guidance on managing SARs in the workplace — especially when IT systems and data security are involved.

What made this episode stand out was the depth of real-world experiences shared. Guest speaker Nia Roberts brought front-line insight, including how to manage expectations and collaborate across departments:

“You need strong communication between data protection and IT teams. It’s essential, especially when you’re dealing with chat logs or historic data held in messaging tools.”

Want More Like This?

The Data Protection Made Easy Podcast is the UK’s leading podcast for privacy professionals, with over 50,000 streams and a thriving live community.

Subscribe to our mailing list by emailing [email protected]
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Find out more about our events, training, and in-person roundtables

Meet the Panel

Looking Ahead

Due to overwhelming demand and an overflowing chat box, we’re exploring a Part 2 to this session, diving deeper into recurring SAR issues, including excessive requests, HR workflows, and lessons from recent case law.

Stay subscribed for updates, and don’t forget to follow us on LinkedIn for all the latest news and event invites.

Special May Promotion: Free SAR Consultations

This month, we’re offering free consultations on SAR handling to any organisation looking to improve their internal process.

Whether you’re struggling with redaction, document searches, or managing requests from difficult cases, speak to one of our experts for practical support.

📩 Simply email us at [email protected] with the subject line SAR Support, and we’ll book in a free 30-minute consultation.

 

Joe Kirk’s Top 10 Tips

Joe Kirk’s Top 10 Tips: Lessons from a Career in Data Protection

In this special episode of the Data Protection Made Easy podcast, long-time host and data protection consultant Joe Kirk reflects on his journey through the world of privacy and compliance—from his early days in sales, speaking to hundreds of DPOs across the UK, to becoming a consultant himself and working with a wide range of clients across every major sector.

As this marks Joe’s final regular appearance on the podcast, we dedicated the session to the Top 10 Lessons He’s Learned over the last four years. These are practical, honest, and experience-based takeaways that he hopes will help current and aspiring DPOs make a meaningful impact in their roles.

Key Themes Discussed

  • How sales and consulting provide different but complementary perspectives on data protection
  • The common challenges DPOs face regardless of sector or organisation size
  • The importance of empathy, curiosity, and communication in building trust
  • Avoiding the “tick-box” mentality and becoming a strategic advisor
  • Keeping your knowledge current in a fast-moving legal and tech landscape
  • How to show your value to the business even when you’re not customer-facing
  • Why DPOs should be involved in decision-making at the earliest possible stage
  • Balancing legal risk with operational reality
  • Encouraging a culture of accountability, not fear
  • The importance of continuous learning – and what Joe would do differently if starting today

These tips are relevant whether you’re new to data protection, already in a DPO role, or even an employer looking to build a successful privacy function.

A Time of Transition for Data Protection Made Easy

Joe’s departure also marks the beginning of a new phase for the Data Protection Made Easy community. As we look to evolve and bring even more value to our subscribers, we’re making some important changes:

Podcast Frequency
We will now host one episode per month, instead of weekly. This allows us to:

  • Deep dive into more meaningful topics
  • Reintroduce guest speakers and expert panels
  • Focus on sector-specific challenges and use cases
  • Provide more actionable takeaways for our listeners

In-Person Events
To complement our podcast, we’ll be launching monthly in-person events, starting with a Housing Sector Roundtable in Leeds. These will be free to attend and packed with:

  • Expert guest speakers
  • Open discussion sessions
  • Networking opportunities
  • Food, drink, and sector-specific guidance

If you’re in the housing sector or work in data protection in Yorkshire, this is a great chance to connect with our team face-to-face. More info coming soon.

Monthly Newsletter
To replace our weekly GDPR Radio news episodes, we’ve launched a monthly email newsletter with:

  • Top stories from the ICO and UK government
  • Regulation changes and enforcement action recaps
  • Insights from the Data Protection People team
  • Highlights from recent podcasts and events

If you’re a subscriber, your first issue should already be in your inbox! If not, sign up here:

Subscribe to the Newsletter

What’s Next?

We’ll soon be publishing a full article on Joe’s Top 10 Tips for DPOs, expanding on the episode with real-life examples, links to useful tools, and guidance from our team. This will be available in the Resource Centre and shared with our newsletter subscribers.

We’ll also be sharing details on our 10-Year Anniversary Celebration taking place in July 2025. If you’re based in Leeds and would like to attend this free event, keep an eye out for the invitation — food, drinks, music, and privacy professionals all under one roof (plus a special guest DJ set from Joe himself!).

Keep in Touch with Joe

While Joe is stepping away from the podcast, you may still hear him pop up as a guest speaker in future episodes or events. He’s made a lasting impact on our community and we’d love for you to stay connected with him: Connect with Joe on LinkedIn

Catch Up On Demand

Listen to Episode 213 – Joe Kirk’s Top 10 Tips on Spotify

Or find us on Apple Podcasts, Amazon Music, and all major streaming platforms.

Thank you to Joe for four years of thoughtful, passionate, and incredibly valuable contributions to the Data Protection Made Easy community. We’ll miss him as a regular host, but we know this isn’t goodbye – just see you later.

GDPR Radio – Episode 212

GDPR Radio – Data Protection News of the Week

In Episode 212 of GDPR Radio, the news-focused arm of the Data Protection Made Easy podcast, our hosts Phil, Catarina, and Joe returned to unpack the latest headlines and developments in the world of data protection.

This interactive session offered an hour of engaging, thought-provoking discussion with a live audience made up of DPOs, legal professionals, cyber security experts, and privacy enthusiasts. As always, we covered what matters most to the data protection community—breaking down key cases, legislative shifts, and industry commentary in a simple, digestible way.

What We Discussed

In this episode, we explored:

  • Latest ICO enforcement actions and what they mean for organisations in regulated sectors

  • Notable data breaches from the past fortnight and the implications for incident response practices

  • The future of AI & consent – how regulators are shaping their approach to emerging technologies

  • UK data reform updates and their impact on DPO responsibilities

  • Plus, we answered live questions from our audience in real-time!

Whether you joined us live or plan to catch up later, Episode 212 was packed with valuable insights for data protection professionals at all levels.


How to Join Future Episodes

We host live podcast episodes every Friday between 12:30 and 13:30. These sessions are free to attend and open to anyone with an interest in data protection or cyber security. To receive weekly invitations straight to your inbox, simply sign up via our website:

👉 Subscribe to Podcast Invites


Earn IAPP CPE Credits

Listening to Data Protection Made Easy live or on-demand may qualify you for Continuing Professional Education (CPE) credits with the IAPP. Attendees can self-certify their participation by keeping a record of attendance or listening history.


Be Part of the Community

The Data Protection Made Easy podcast isn’t just a podcast—it’s a growing community. With over 1,500 subscribers and 200+ episodes, we’re proud to offer a space where professionals can learn, share ideas, and stay ahead of the curve. Each week, our live chat is buzzing with questions, opinions, and useful links from fellow practitioners.


Catch Up On Demand

Missed the live session? You can listen to Episode 212 and all previous episodes on Spotify, Amazon Music, Apple Podcasts, or wherever you get your podcasts.

🎧 Listen to GDPR Radio – Episode 212 on Spotify


Let us know what you thought of the episode or share a topic you’d like to see covered in a future edition of GDPR Radio!

How to Stand Out as a DPO

How to Stand Out as a DPO – Episode 211 of the Data Protection Made Easy Podcast

In this week’s episode of the Data Protection Made Easy podcast, our expert hosts Joe Kirk, Catarina Santos, and Phil Brining came together to explore one of the most popular and debated topics in the data protection space: what it takes to stand out as a Data Protection Officer (DPO) in today’s fast-evolving landscape.

With over 200 episodes under our belt, Data Protection Made Easy has always been about honest, accessible conversations—and this one was no different. Episode 211 sparked lively discussion, professional debate, and some healthy disagreements between our hosts, all of which reflect the complexity and diversity of views in our field.

We tackled the key ingredients that make a truly exceptional DPO:

  • What skills separate a great DPO from a good one?
  • How much does certification and formal training matter?
  • Is legal knowledge more important than technical awareness?
  • How do you build influence within an organisation as a DPO?
  • What are hiring managers really looking for in a data protection lead?

One of the biggest takeaways from this episode is that there is no single “correct” route to becoming a successful DPO. Some of our speakers emphasised strong legal backgrounds, while others focused on communication, pragmatism, and an understanding of real-world implementation. It’s this range of perspectives—and the opportunity for our community to challenge and expand on them—that makes our podcast so valuable.

Whether you’re:

  • An aspiring DPO looking to break into the industry,
  • A practicing DPO interested in sharpening your approach,
  • Or an employer or recruiter trying to understand what makes an impactful DPO,

this episode is packed with practical advice, reflection, and a few strong opinions that will get you thinking.


Want to Join the Conversation?

Our sessions are completely free to join and happen live every Friday from 12:30 – 13:30 (UK time) via Microsoft Teams. When you attend live, you’ll be part of our interactive chat, gain access to shared resources, and have the opportunity to ask questions or share your perspective.

If you can’t make it live, don’t worry—every episode is available on Spotify and all major streaming platforms so you can catch up any time.

👉 Subscribe to join future episodes
🎧 Listen back on Spotify
📩 Or sign up to receive weekly invites straight to your inbox.


Up Next: Episode 212 – GDPR Radio

Join us next Friday for GDPR Radio, our fortnightly roundup of data protection news, enforcement actions, and thought-provoking discussions. If you want to stay ahead of regulatory developments and understand what’s shaping our industry in real time, this is the place to be.

Thank you for being part of the Data Protection Made Easy community—see you next week!

 

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AI Tools & GDPR What You Need to Know (1)
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AI Tools & GDPR: What You Need to Know

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29 May 25 10:00 - 2:00 pm

Housing Sector SARs

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