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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...

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UK financial services data security and cyber resilience: UK GDPR, FCA requirements, FCG guidance, outsourcing and operational resilience, critical third parties oversight, and CBEST

Practice notes
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Legislative framework for Data security

UK GDPR

The Assimilated Regulation (EU) 2016/679—known as the UK General Data protection Regulation (UK GDPR)—is the principal source of data protection law in the UK. It is complemented by the Data Protection Act 2018 (DPA 2018). For more on the UK GDPR and the DPA 2018, see Practice Notes: UK GDPR—the basics and The Data Protection Act 2018.

FCA data protection requirements

The FCA’s data protection requirements are outlined on its Data protection webpage. Customer data means any identifiable personal information a firm holds or retains about a customer. This may exist in any format or medium and includes:

  • details gathered by the firm to meet anti-money laundering obligations
  • data collected by the firm as part of the customer on-boarding process
  • information secured by the firm to satisfy its suitability and appropriateness requirements, and
  • any other identifiable personal information the firm may hold about a customer, such as address, date of birth, National Insurance number, passport details, family circumstances, tax and income records

The FCA states that data security is not purely an IT problem, nor is it just an issue for large firms. The FCA emphasises that organisations of every size should consider...

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Web page updated on 22/05/2026

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