Data sharing and transactions

This subtopic discusses the processing and sharing of personal data by controllers and processors (as defined below) under the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (the UK GDPR). It also links to guidance relating to the EU’s General Data Protection Regulation, Regulation (EU) 2016/679 (the EU GDPR) that is applicable in the EEA, since those data protection regimes will often need to be considered together. This Overview provides a high-level introduction to the subtopic and signposts more detailed guidance housed within it.

Guidance on equivalent laws under the EU GDPR is available in our EU Law practice area, see: EU GDPR regime (EU Law)—overview.

This Overview assumes a degree of familiarity with key data protection concepts. For a general introduction to data protection law, see the tab on ‘key principles and concepts’ in the UK data protection law collection.

Processing by controllers and processors

Processing of personal data by controllers and processors is subject to extensive regulation under the UK GDPR regime.

Subject to certain provisions of the Data Protection Act 2018 that apply in particular circumstances, the UK GDPR generally

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Latest Information Law News

Information Law weekly highlights—5 March 2026

Welcome to this week’s edition of the Information Law weekly highlights a hand-picked summary of news analysis, updates and new content related to laws governing the use and dissemination of information and personal data. Each week these highlights focus on developments in key topics such as data protection, ePrivacy, cybersecurity, breach of confidence, misuse of private information, and defamation.

Court’s inherent jurisdiction and injunctive relief in harassment cases (Titan v Okunola)

Dispute Resolution analysis: This case concerned the court’s power to grant an injunction to restrain a litigant from sending abusive communications to an opposing party’s legal team. The High Court dismissed the application, stating that there was no ‘sound jurisdictional basis’ for such relief. The Court of Appeal held this was wrong: the court does have inherent jurisdiction at common law to protect the integrity of its own proceedings. However, the court agreed that refusal of the injunction was appropriate, as there was no ongoing risk and other discretionary factors weighed against relief. The judgment provides guidance for practitioners considering how to address disruptive litigation conduct. It clarifies the scope of the court’s inherent jurisdiction where behaviour poses a serious risk to the administration of justice. Where the conduct falls short of contempt, practitioners seeking such injunctions must also consider the impact of Article 10 ECHR, section 12 HRA, and litigation immunity. The case further highlights appropriate procedural routes and key discretionary factors relevant to injunctive relief. Written by Sarah Ellington, partner at Watson Farley & Williams LLP.

Data by any other name—Court of Appeal reverses Upper Tribunal’s ruling on the protection of ‘personal data’ (DSG v ICO)

Information Law analysis: In this case, the Court of Appeal unanimously allowed the appeal brought by the Information Commissioner’s Office (ICO), holding that it is sufficient that data which has been subjected to unauthorised or unlawful processing by a third party still constitutes personal data from the perspective of the data controller, even if it is pseudonymised ‘in the hands of’ the data controller and therefore anonymised ‘in the hands of’ the attacker. Accordingly, the court held, the data controller is required to take ‘appropriate technical and organisational measures’ (ATOMs) to protect that personal data against such hackers, even where those third parties cannot themselves identify the individuals to whom the data relates. Even though this judgment is under the Data Protection Act 1998 (DPA 1998), this decision is significant as it confirms, in terms equally applicable to the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR), that the scope of the security obligation is not diminished merely because stolen or exfiltrated data would be anonymised in the hands of the third party with unlawful access. This development expands and makes more pressing the obligation on controllers to assess and guard against a broader range of threats—including ransomware, data destruction, and bulk exfiltration, regardless of the attacker's capacity to re-identify data subjects. Written by Adelaide Lopez, senior associate at Wiggin LLP.

Commission consults on draft Guidance on EU Cyber Resilience Act

The European Commission has launched a consultation on a draft Communication intended to provide guidance on the interpretation and practical application of Regulation (EU) 2024/2847, the EU Cyber Resilience Act (CRA). As required under Article 26(1) of the CRA, the proposed non-binding guidance is designed to assist manufacturers, developers and other stakeholders in better understanding their obligations under the CRA and to ensure a consistent approach across the EU, with a particular focus on supporting microenterprises and small and medium-sized enterprises in meeting compliance requirements. It covers the following key areas: (1) the scope of the CRA, including free and open-source software and the definition of substantial modification; (2) support period requirements; (3) important and critical products and core functionality assessments; (4) cybersecurity risk assessment; (5) remote data processing and (6) other elements such as reporting obligations, vulnerability handling and the interplay between the CRA and other EU legislation.

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