Under the leadership of Information Commissioner John Edwards, it is fair to say the UK’s Information Commissioner’s Office (ICO) has implemented a strategic shift in its enforcement approach, emphasising engagement and systemic change over the imposition of substantial fines. This philosophy is grounded in the belief that collaborative efforts and remedial actions are more effective in achieving compliance than punitive financial penalties.

Upon his appointment, Edwards articulated a vision for the ICO that prioritised meaningful compliance outcomes over the issuance of fines. He has consistently emphasised the importance of regulating for ­outcomes rather than outputs, suggesting that the ICO’s role should focus on fostering a culture of ­compliance through engagement and education.