| Commentary

(5) Penalty notices

| Commentary

(5)     Penalty notices

The ICO may impose fines by issuing a written penalty notice requiring an employer to pay the ICO a specified amount if it is satisfied that the employer has failed to comply with the obligations for which an enforcement notice can be issued (see para [194.281]), or if the employer has failed to comply with an information notice, an assessment notice or an enforcement notice (DPA 2018 s 155(1)). The potential fines for infringement of data protection obligations are well publicised and severe.

A fine of up to £17.5m or 4 per cent of

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