Category: Other Information Law

I have come to the conclusion that the Government does not care whether or not the UK’s Adequacy Agreement with the European Commission continues after its expiry (latest in mid-2025). This conclusion is based on the well-publicised deficiencies in the two consultation exercises of the DCMS (on data protection) and MoJ (on human rights) and the recent report of Joint Parliamentary Committee on Human Rights into the MoJ proposals.  This latter Report carries many warnings concerning the Government’s intent to

This blog reviews the new Information Commissioner’s speech at the end of March to a group of IAPP data protection specialists.  The speech contained statements that I don’t recognise as being consistent with the DCMS proposals for changing the UK_GDPR. One passage in the speech related to the general importance of the need for a lawful basis for many actions; whether that lawful basis relates to stop and search by the police, or the processing of personal data by a

The Ministry of Justice (“MoJ”) Consultation,  “Human Rights Act Reform: A modern Bill of Rights” (the “Consultation”), contains proposals that tips the balance between “respect for private and family life.” (A.8) and freedom of expression and to impart information (A.10) in favour of the latter (A.10). Quoting a single ECHR judgment (ML v Slovakia) as justification for the changes, the Consultation fails to realise the judgment does the precise opposite.   A case which initially appears to be one where the

“Operation Save Big Dog” is the name given to the effort expended to ensure the Prime Minister survives, despite several after-hours, alcohol-fuelled, “office-gatherings” at 10 Downing Street during COVID-lockdown.  This Operation has coincided with the need to remind the British public of the pure brilliance of the Brexit decision. Hence last week’s announcement of a ‘Brexit Freedoms’ Bill” (with the promise to use Ministerial powers push through major change) and the publication of a policy document entitled “The Benefits of

The Ministry of Justice (MoJ) Consultation,  “Human Rights Act Reform: A modern Bill of Rights”,  has the potential to significantly undermine the application of UK’s data protection regime. These MoJ proposals are in addition to the DCMS proposals which also weakened the UK_GDPR (discussed in various blogs last November).  Neither the DCMS nor the MoJ make any reference to the fact that their separate public consultations are connected when data protection is concerned.  One wonders how this fundamental omission was

First of all Happy New Year; I hope the recent festive excitement was not too infectious.  Indeed, with the risky policy of letting Omicron rip, let us hope there are not too many ex-data subjects, possibly as a result of the collapse of essential services. I am starting the Year with a real treat; I have been given permission to publish the personal views of Rosemary Jay as submitted to the DCMS consultation “Data: a new direction” (see link at

This blog comprises the response of Amberhawk Training Limited to the DCMS Consultation document “Data: a new direction”  (the “Consultation”).  Amberhawk is a training company established in 2000; its Directors have over 40 years’ experience in training those who are responsible for data protection in an organisation. The response is over 15,000 words and takes the form of 7 blogs, each of which are about 2,300 words long.  They were published during the consultation period which ends tonight and have been

The DCMS Consultation document “Data: a new direction”  (the “Consultation”) proposes to tip the balance between the interests of controllers and the interests of data subject in favour of the controller.  This blog looks at the proposals, not in the context of how beneficial they are for controllers, but rather in the context of how they weaken the privacy protection afforded to data subjects. The weakening provisions being mooted include: Introducing a fee arrangement for subject access which has a