Sunday 21 March 2021

My Top Tips for the UK’s Next Information Commissioner


The UK’s data protection community isn't easy to please. Privacy is big business these days, and many of its opinion formers take to social media platforms to generate noise and controversy. 




Because noise and controversy sells. It sells seats at privacy conferences and it sells consulting time – which can be dangerous when there are no entry barriers to the privacy consulting trade. Noise and controversy are also the lifeblood of the privacy NGOs. Most exist to please their funders, so expect fireworks from these folks, too. 


Amidst the privacy hype and noise, here are my top tips to make your life less challenging than it otherwise will be:


1.    Work from Wilmslow. Many privacy pros may work remotely, but you've been selected to set an example and to lead from the front. You will have a huge team at your disposal and they need to know that you’re as committed to Wilmslow as they are.

2.    Embrace conflict. Whatever you try, you’re likely to be opposed, either from the privacy pragmatists or the privacy Taliban. Don’t take conflict personally. You’re just doing your job.

3.    Expect to be opposed from within the ICO, as well as from without. The organisation has grown so fast that it’s impossible to expect everyone in it to share the same outlook as you. You may not even realise how you are being undermined you until some brave DPO quietly shares with you their experiences of working with your staff.

4.    Don't think you will get it right all the time. Key parts of privacy laws are in a right mess, and any attempt to help clarify or simplify the law can easily backfire, especially if it requires primary legislation.

5.    The UK may have left the EU, but it hasn't (yet) escaped from the acquis of European privacy law. In helping deliver the Government’s National Data Strategy, it’s OK to embrace a ‘UK First’ approach. You are the UK’s Information Commissioner. You are not someone who has been parachuted in to challenge British values.

6.    Relax. The £200,000 salary won’t adequately compensate you for what you will experience, but you’ll only serve a single seven-year term in office. By the end, you’ll (probably) have received a nice gong and a lucrative offer from another organisation.