Jurisdiction(s):
United Kingdom

Key definition

Data definition

What does Data mean? In legal practice, data describes information recorded in any form—especially electronically stored information (ESI)—organised or capable of being organised for a particular purpose, and capable of being processed or transmitted. It covers structured and unstructured material such as database entries, spreadsheets, emails and messaging content, documents, images, audio/video, metadata, system logs, backups and cloud-stored content. Data is not defined in the Civil Procedure Rules of England and Wales (nor generally in equivalent court rules), which instead use the broad concept of a document as anything in which information is recorded, encompassing electronic data and metadata. Statutes define data contextually: UK GDPR...

Data Protection Officers for UK law firms under the UK GDPR: mandatory thresholds, voluntary appointments, conflicts, external DPOs, duties and protections

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Practice notes

Under the UK GDPR

Certain firms must name an individual to serve as their Data Protection Officer (DPO). This Practice Note explains when a DPO is mandatory to meet UK GDPR requirements, and weighs the benefits and drawbacks of appointing a DPO on a voluntary basis. It also considers who should act as the firm’s DPO, the DPO’s responsibilities, and the risk of conflicts of interest. It should be read alongside the DPO appointment decision tree. For further detail on accountability and governance under the UK GDPR, see Practice Note: The UK General Data protection Regulation (UK GDPR)—Accountability and governance. This Practice Note is grounded in the UK GDPR and the following guidance:

Information Commissioner’s Office (ICO) guidance: UK GDPR guidance and resources, Accountability and governance, Data protection officers
Guidelines on DPOs issued by the Article 29 Data Protection Working Party and later endorsed by the European Data Protection Board (EDPB guidance on DPOs)—although EDPB guidance is no longer directly relevant to, or binding under, the UK regime, the ICO has stated it may still offer useful direction on particular matters
SRA guidance: Confidentiality of client information
Council of Bars and Law Societies of

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Web page updated on 21/05/2026

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