EP NowStoreAcademySupportProduction LotProducts by Country
Legal & Compliance Home

Cabinet Office Fined £500,000 for Disclosing Addresses of High-Profile Individuals

The Information Commissioner’s Office (ICO) has fined the Cabinet Office £500,000 for accidentally publishing the postal addresses of 2020 New Year Honors recipients online. 
July 9, 2022
Cabinet Office fined for disclosing addresses

This decision comes hot on the heels of other ICO penalty decisions, including its recent decisions to fine two charities £10,000 and £25,000 for breaching the UK GDPR. As this latest decision concerns the data of high-profile individuals, there are a number of takeaways for production companies.

What happened?

In December 2019 the Cabinet Office accidentally published on GOV.UK a CSV file containing the names and postal addresses of more than 1,000 people included on the New Year Honours list. The list included individuals from a wide range of professions, including high-profile individuals.

A member of the Government Communications Team came across the breach “by chance” and alerted the Cabinet Office Press Team. The file was permanently deleted from the website two hours and 21 minutes after it was published. Before its deletion, it was accessed 3,872 times from 2,798 IP addresses.

The Cabinet Office reported the breach to the ICO within 72 hours of discovering it.

The decision

Following an investigation, the ICO found that the Cabinet Office had breached Article 32(1) of the UK GDPR because it had failed to put in place appropriate technical and organisational measures which reflected the risk associated with the processing of the data.

The ICO initially issued the Cabinet Office with a notice of intent to impose a penalty of £600,000. However, the Cabinet Office contested the fine and the ICO subsequently reduced it to £500,000.

Despite the reduction, this is still a heavy fine. Among other things, the ICO based its decision on the following factors: 

  • Although the file wasn’t online for very long, the publication of the list was a high-profile event and the list was accessed nearly 4,000 times. 
  • Although the information constituted basic identifying information and not sensitive data, it concerned a large number of individuals, including high-profile individuals. 
  • While documents regarding best practice for handling data had been accessible to employees on the Cabinet Office’s intranet, these were not regularly updated or promoted. 
  • While the Cabinet Office had implemented mandatory data protection training before the incident, not all employees who were involved in the processing of personal data had received training in the past two years.
  • The Cabinet Office had also identified that there were issues with access restrictions often being imposed “too late,” resulting in some personal data being accessible to entire teams.
  • The data breach could easily have been avoided, but the Cabinet Office had failed to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. 

Key takeaways for production

This decision has a number of key takeaways for production companies and their teams: 

  • As the ICO is continuing to crack down on organisations which don’t have sufficient safeguards in place to protect people’s data, it’s essential to have adequate security measures in place. (Not sure where to start? See how the Production Portal can help you to protect your data.)
  • Personal information pertaining to high-profile individuals poses a particular risk. This includes basic contact information, such as addresses and phone numbers (swapping paper documents (eg, start forms, contracts and call lists) for digital versions can help to mitigate this risk).
  • It’s important to have appropriate data protection policies in place and a means to update and promote these through ongoing trainings. It’s also important to have a clear audit trail of who’s read and agreed to your policies.
  • Access to personal data should be restricted to those who need it and updated as soon as crew change roles.

For more information on how to secure your production data, check out our guide to information security.

Topic: UK

Related Content

EP News_SQUARE_Breaking Down Barriers-How Leading UK Organisations are Driving Inclusion in Film and TV

Breaking Down Barriers: How Leading UK Organisations are Driving Inclusion in Film and TV

6/17/2024
Notable UK training bodies and industry partners gather to reaffirm their mission to drive change and...
Woman looking at a laptop

20 IR35 Terms Every Production Worker Should Know

5/28/2024
Find out how to apply the UK’s IR35 rules to your film and TV productions with this helpful overview.
Master Series Thumbnail–UK indie film tax credit

Boost Your Budget with the Independent Film Tax Credit

5/9/2024
Learn how to maximize UK incentive dollars with the new IFTC!
Fully Focused-Thumbnail-480

Entertainment Partners and Fully Focused Partner to Support the Future of UK Production

5/7/2024
New partnership aims to foster the next generation of UK production professionals and break down barriers...

Spotlight: Lloyd Gunton, UK Tax Credit Expert

5/7/2024
Meet the creative sector tax expert helping EP clients from indies to major studios maximize incentives...
Cameraman filming outside in a field

HMRC Announces Changes to Claiming UK Creative Sector Tax Incentives

4/26/2024
What productions should know about the increased disclosure requirements under the UK's Audio-Visual...
EP Blog-Bob Clarke-Mama Youth

Celebrating (Almost) 20 Years of MAMA Youth Project

4/17/2024
UK charity’s founder, Bob Clarke, shares how this unique initiative is breaking down barriers to...
Producer and actor standing on a film set

How to Prepare for an Audit: Tips for UK Productions

4/16/2024
Discover key strategies UK film and TV production companies can use to effectively prepare for an audit.
Topic: UK
More
Camera man and production crew on a film set

Curious About Co-productions? What Producers Need to Know.

4/9/2024
Discover the advantages, requirements, and strategies for successful co-productions in the film industry.
National Film and Television School

Entertainment Partners To Provide Funding For Future Assistant Directors And Floor Managers

3/28/2024
Two new scholarship opportunities are now available for those looking to train in the field of assistant...

What Does the UK’s New Independent Film Tax Credit (IFTC) Mean for Productions?

3/7/2024
As the UK government strengthens its support for productions, find out what the latest changes to the...
Four panelists discuss co-production-square

Unlocking the Myths and Benefits of Co-Production

2/15/2024
Learn the difference between an official co-production and PSA, and how to leverage these opportunities to...
EP Newsroom-Thumbnail-PGGB

Million Youth Media Wins The Duke of Edinburgh Film & TV Inclusion Award 2024 at PGGB Talent Showcase

2/14/2024
The Duke of Edinburgh Film & TV Inclusion Award presented to Million Youth Media, an organisation offering...
Blue square with white letters and UK flag: Changes to UK Paternity Leave Regulations

Changes to UK Paternity Leave Regulations

1/19/2024
Effective March 8th, modified paternity leave to provide more flexibility for UK fathers.
Topic: Alerts
More
Big Ben, London

5 Things to Consider Before Transitioning to the UK’s New AVEC Regime

1/16/2024
A comprehensive overview to help determine if you should use the UK’s new incentive regime to fund your...
Blue tile stating UK announces minimum wage updates

UK Government Announces Minimum Wage Updates

12/5/2023
National Living Wage and National Minimum Wage rates increase for 2024.
Master Series Thumbnail Square UK Productions

UK Production: Sites, Services and Studios

10/20/2023
Learn about UK incentives, infrastructure and production innovation spanning from London to Wales,...

Entertainment Partners Makes Commitment to UK Production with Film & TV Partnership Programme

10/12/2023
Find out how EP is partnering with the leading UK training organisations to close the skills gap, increase...
Entertainment Partners Logo Thumbnail-square

NFTS and Entertainment Partners (EP) Establish Partnership to Support the Future of Film and Television Production

10/5/2023
By supporting the National Film and Television School through this new partnership, Entertainment Partners...
Newsroom-Advanced-Television-Logo-Thumbnail

NFTS, Entertainment Partners establish partnership

10/5/2023
EP the entertainment payroll and production technology company joins as a prominent new Patron of the...
British-Cinematographer-Logo-Thumbnail

NFTS and Entertainment Partners (EP) establish partnership

10/5/2023
The National Film and Television School (NFTS) announces a new partnership with Entertainment Partners...
UK Right to Work Penalties to Triple in 2024

UK Right to Work Penalties to Triple in 2024

9/26/2023
Find out how your production can prepare for the increased penalties for employing a worker who doesn't...
Topic: Legal
More
EP Blog_SQUARE_Spread of UK Production

Outside of London: How the UK Production Industry Spread Beyond the Capital

9/21/2023
Film and TV production outside of London (OOL) is now an integral part of the UK, with world-class media...
Topic: UK
More
Expert Advice_Sam Collett

Spotlight: Sam Collett, UK Production Accounting and Incentives Expert

9/19/2023
Meet the Senior Partner at FLB Accountants, an Entertainment Partners company specializing in UK media and...
Master Series_UK Incentives Panel_Square

What's Changing in UK Production Incentives

9/15/2023
Learn about the recent changes to the UK Creative Sector Tax Credits and how they might impact your next...
EP Blog_SQUARE_UK cultural test

Understanding the UK Cultural Test

9/12/2023
Find out whether your film or TV show will pass the UK’s Cultural Test, a key step in qualifying for the...

Payroll & Finances

PayrollResidualsSmartStartSmartTimeProduction PortalEP On LocationSmartAccountingEP LiveSmartPOCASHétPayPaymaster Rate GuideEP ResidencyMoneypenny

Manage Multiple Productions

AssetHubSmartHub

Additional Services

Academy
Subscribe now

Be an industry insider with EP's
newsletters and alerts

LegalPrivacy NoticeSecurity
© 2024 Entertainment Partners. All rights reserved.