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ICO25: practical guide to the UK ICO's 2022–2025 strategy—objectives, enforcement priorities, guidance pipeline, KPIs and timelines for data protection and FOI practitioners

Practice notes
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October 2022 saw the Information Commissioner’s Office (ICO) unveil ICO25, a three-year strategy running to October 2025, intended to drive openness and, in turn, bolster legal and regulatory clarity for organisations, especially those with a commercial stake in processing personal data and innovating in this field.

This Practice Note offers a pragmatic digest of that mission, and sets out how advisers can support those they counsel to plan and prepare, based on what is currently known about forthcoming themes. It highlights practical steps professionals can take to align plans with the anticipated direction of travel during the period.

It assumes readers are conversant with all facets of data protection law, including the regulator’s role and the scope of the supervisory authority too.

Those less familiar may wish to begin with Practice Note: The Information Commissioner’s Office (ICO). The UK data protection law collection and Data protection law—new starter guide may likewise prove useful.

What is ICO25? Overview

Under Information Commissioner John Edwards, ICO25 marks the ICO’s first effort to set out short- and medium-term objectives, both internal and external, in ways that are tangible, measurable, and readily actionable.

It characterises itself as a plan explaining why the ICO’s work is...

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Web page updated on 21/05/2026

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