ICO enforcement and focus on children’s privacy

Organisations should ensure they take steps to mitigate risks to children. By Nicola Fulford, Jabeen Rizvi and Kathleen McGrath of Hogan Lovells.

Around this time two years ago, the new Information Commissioner, John Edwards, began his role. A previous member of OECD’s Informal Group of Experts on Children in the Digital Environment, the new Commissioner’s opening statement emphasised rights, responsible innovation, and empowering people through privacy(1). As we reflect on the ICO’s actions two years on, their focus on enforcing children’s rights at the intersection with modern technologies has gained intensity.


The comments of John Edwards in his opening speech were reflected in the ICO’s later published strategic plan, ‘ICO25’(2). The plan sets out the purpose, objectives, and values of their new approach, and how the ICO will achieve it by 2025. The ICO specifically outlined four objectives: safeguard and empower people, enable innovation and responsible growth, promote openness and transparency and develop the ICO’s culture.

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