Tag: ransonware

The UK’s data-protection landscape is evolving fast, and SMEs are now directly exposed to enforcement action once largely associated with public bodies or large multinationals. As the BDO enforcement trends analysis reviewing ICO enforcement trends 2025,  highlights, the ICO is increasingly focused on fundamental compliance failures rather than technical edge cases, meaning SMEs face the same expectations as larger organisations.

To help UK SMEs stay ahead, this guide breaks down the three most prominent ICO enforcement themes in 2025 and explains how each relates directly to the core duties under UK GDPR.

ICO Enforcement Trend 1: DSAR Delays & Right-of-Access Failures

The ICO continues to treat DSAR delays as one of the most serious indicators of poor governance. This theme appears repeatedly in enforcement notices and aligns closely with the BDO analysis.

A recent example is the enforcement notice issued to South Wales Police, requiring the organisation to clear a backlog of more than 350 overdue SARs by mid-2026.

Although policing bodies sit in a unique context, the principle is identical for SMEs:
a delayed, incomplete, or mismanaged DSAR is a governance failure, not an administrative error.

Why SMEs are vulnerable

• DSAR processes are often informal or undocumented
  
• Staff rely on untracked shared inboxes that hamper compliance
  
• Manual redaction takes longer than expected and slows response times
  
• Identity verification checks are inconsistent or incomplete
  
• No clear owner is assigned to coordinate DSAR responses

Consequently, SMEs often fail “by accident”, simply because processes were never clearly built.

What SMEs should do

• Implement a formal DSAR register
• Use standardised verification templates
• Assign responsibility for triage and drafting
• Create a redaction decision record
• Test your DSAR workflow every six months

See how Athlex Data Protection can help you with your UK GDPR compliance.

To strengthen your position, Athlex Data Protection includes DSAR review as part of its Free UK GDPR Compliance Audit.

ICO Enforcement Trend 2: System Errors & Data-Accuracy Failures

While many SMEs assume breaches are caused by sophisticated threat actors, the ICO’s recent fines show that basic security failings, particularly around access control and system configuration, remain the driving force behind most incidents. This is why BDO identifies weak security controls as a recurring enforcement theme.

A clear example of this is the £3.07 million fine issued to Advanced Computer Software Group (“Advanced”), a major processor used across the UK health and education sectors.

What happened

A ransomware attack exploited several preventable vulnerabilities, including:

• inadequate access controls,
• outdated software components,
• unpatched critical systems, and
• insufficient segregation of sensitive data.

Because Advanced was acting as a data processor, the incident demonstrated that processors are not insulated from ICO enforcement. Importantly, the ICO highlighted that robust Article 32 security measures apply equally to processors and controllers — a point many SMEs overlook when relying on third-party suppliers.

Why this matters for SMEs

Many SMEs rely on external IT providers, SaaS dashboards, or outsourced infrastructure. Consequently, they often inherit a false sense of security. Yet, as the Advanced case shows:

• unpatched systems,
• misconfigured access rights, and
• weak administrator controls can create breach pathways that affect both the processorand its clients.

Furthermore, the ICO’s commentary stresses that technical misconfiguration is increasingly treated as a governance failure, not an unavoidable risk. In other words, SMEs are expected to demonstrate continuous security management – not reactive fixes after an incident.

What SMEs should do now

To reduce exposure to similar enforcement action:

• Conduct regular patch-management reviews and document them.
• Enforce multi-factor authentication onevery administrative and remote-access account.
• Validate that third-party systems use secure configuration baselines.
• Request evidence: recent pen-test summaries, MFA logs, and architecture diagrams showing data segregation.

ICO Enforcement Trend 3: Supply-Chain & Vendor Risk Is Now the Biggest Exposure

BDO notes that third-party suppliers are involved in a significant proportion of enforcement cases. This is evident across recent ICO actions.

A major example is the £14 million fine issued to Capita following a cyber incident that exposed the data of over 6 million people.

The ICO criticised:

• slow isolation of the breach,
• insufficient monitoring,
• weak patching practices, and
• inadequate oversight of third-party systems.

Similarly, the Upper Tribunal’s Clearview ruling confirmed that even overseas vendors fall under UK GDPR if they monitor UK residents.

Why SMEs must pay attention

SMEs are more dependent than ever on external providers – IT contractors, payroll services, marketing platforms, CRMs, SaaS tools, cloud storage, etc. Consequently, the regulator expects SMEs to:

• verify supplier security
• assess processors before onboarding
• maintain a vendor register
• require evidence of compliance
• include audit rights and termination clauses

In other words, your compliance is only as strong as your weakest vendor.

What SMEs should do

• Inventory all suppliers with data access
• Request evidence: certifications, test summaries, logs
• Ensure processor contracts meet Article 28 requirements
• Assess vendors annually (high-risk: quarterly)

The Athlex Data Protection free audit highlights exactly where your vendor chain poses compliance risk.

ICO Enforcement Trend 4: Governance, Documentation & Accountability Are Under the Microscope

BDO’s report highlights that the ICO is increasingly examining how decisions are made, not just whether breaches occur. Good governance – leadership awareness, documented decisions, risk logs, and internal reporting structures — is now a major enforcement factor.

This aligns with the ICO’s call for views on new enforcement-procedural guidance, signalling more transparent and structured regulatory processes.

This means SMEs are expected to show:

• clear data-protection ownership
• leadership engagement
• meaningful internal reporting
• documented risk assessments and decisions
• evidence of proactive compliance

How SMEs Can Stay Ahead – Starting Today

To prepare for these enforcement trends, SMEs should immediately focus on:
✔ DSAR workflows
✔ Data-accuracy controls
✔ Vendor oversight
✔ Incident readiness
✔ Governance documentation

And the simplest way to begin?

Use Athlex Data Protection’s Free UK GDPR Compliance Audit tool.

To read more about the biggest UK GDPR risks for SMEs, see our blog: Inside Out: Why Insider Risk Is the Biggest UK GDPR Blind Spot for SMEs.

 It covers DSARs, access controls, vendor risk, system accuracy, governance, and incident readiness –  all mapped into a clear action plan.