ICO consultation on draft Corporate Strategy 2026 - Which? response

We welcome the opportunity to comment on the ICO’s new draft Corporate Strategy for 2026-2028. 

Our response highlights the need for the ICO to maintain focus on its core functions which centre on upholding information rights and promoting data privacy for individuals. Throughout the strategy, these priorities should be reflected and not neglected in favour of actions targeted more strongly towards secondary growth and innovation objectives. 

• We disagree with the proposed purpose stated in the draft strategy, ‘to build trust in responsible UK data use and innovation’, because it lacks reference to core ICO responsibilities of upholding and ensuring data rights. 
• We support the intentions that are reflected in the four strategic outcomes but suggest these should be reframed for better clarity which would strengthen the strategy’s messaging. As written, they lack focus on the impacts that can be directly achieved by the ICO’s work on data and information protections. 
• We support the areas selected as the four identified regulatory priorities but disagree with the framing of the priorities. 
• We suggest the ICO should reframe these to align more closely with their remit and promote more appropriate, understandable goals. 
• We are highly supportive of the included commitment to enforcement measures set out in the strategy and encourage the ICO to maintain and follow through on this intention to better ensure achievement of the strategy’s potential impacts.