Take care before you share: The ICO’s draft code of practice

Private sector organisations need to pay attention too as the code recommends data sharing agreements to support accountability. By Rebecca Cousin and Cindy Knott of Slaughter and May.

In July, the Information Commissioner’s Office (ICO) published a draft Data Sharing Code of Practice (“the code”). This is a noteworthy piece of draft guidance as it will have wide-ranging application. In addition, much has changed in the data protection world since the current Data Sharing Code of Practice was published in 2011. Now is therefore a good time for organisations to review their approach to data sharing.

Whilst much of the code contains helpful guidance, it is likely to be challenging to follow in its current form in all circumstances. A number of organisations, including the City of London Law Society, submitted comments to the ICO during the consultation period for the code, which closed on 9 September. It is hoped that these comments will be taken into account by the ICO to make the final version of the code as useful as possible.

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