Data protection in advertising technology, or “adtech”, has been an area of focus for the Information Commissioner’s Office (ICO) for some time now, with the regulator first launching its investigation into standards of privacy in the industry three years ago in early 2019. A damning update report (the 2019 Report)(1) was issued in June of that year, identifying numerous data protection compliance issues across the adtech ecosystem and setting a clear regulatory expectation that controllers in the industry should re-evaluate their approach to compliance. Further activity was expected throughout 2020, but the coronavirus pandemic caused the investigation to be put on hold until January 2021.