ICO Enterprise Data Strategy: Foreword and introduction

Foreword by John Edwards, Information Commissioner

In 2022, we launched our ICO25 strategy to transform the ICO to become a regulator equipped to face the challenges and opportunities of a digital and data-driven world. At that time, we recognised the importance of our own use of data in this mission by committing to develop a data strategy. I’m delighted to present the draft of this strategy today.

Having a data strategy is crucial in setting out how we develop, manage, govern and use our data assets in pursuit of our purpose: to empower you through information. Whether it’s providing deep insights into the needs of our customers, identifying and predicting instances of harm, guiding prioritisation and decision making, or underpinning our use of automation and AI, it’s clear that data is a key part of the modern organisational fabric.

The ICO has another opportunity, though. As a regulator, we’re shifting our guidance away from “don’t do” to “how to”. In a similar way, our data strategy is setting an ambitious vision to “show, not tell”. We aspire to be an exemplar for responsible innovation in the use of data – one that can inspire and guide others through our own transformation.

Introduction by Rob Holtom, Executive Director - Digital, Data and Technology (DDaT), Transformation and Delivery

The ICO’s data strategy has its foundation in our organisational goals and strategy. As such, it’s not just about what we do in our data teams or for those with “data” in their job title. On the contrary, it has impact and application across all parts of the organisation – from where data is captured and created, to how we develop the right skills and culture, how it’s put to use, and how we protect ourselves from its potential for misuse.

We needed a solid, evidence-based foundation of where we were starting from. So, a core activity was completing a comprehensive and organisation-wide data maturity assessment. We achieved this through engaging with more than 200 people across the ICO to get their unique insights into areas of existing strength and where we needed to uplift our capabilities.

Understanding capability gaps is not enough, however. We needed to get a better sense of our data culture: what were the beliefs and behaviours that supported our mission, and what was holding us back. And, we needed to identify how data could provide real, tangible value to the ICO and our customers, through a set of achievable but ambitious lighthouse projects.

Together, these elements have led to the strategy you see before you. It puts our vision – to be an exemplar for responsible innovation in the use of data – front and centre. It’s supported by four key principles that speak to the data culture we want to see: democratic, disciplined, daring and dignifying. It’s shamelessly value-oriented – seeking out the benefits that data can achieve when put to use, and approaching our actions through this lens. And underpinning this, it sets out the ways we need to uplift our data capabilities to drive true transformation.

The journey so far has been exciting, illuminating and not a little bit daunting! But we know that the next stage – putting it into action – will bring the proof points that’s we’re heading in the right direction. For this, we need your help. As part of our mission to inspire the wider data industry, we’re opening this draft up to public consultation to get the widest possible range of input and ideas. By being open about the journey we’re on, we believe we can be better informed and better inform others about what “responsible innovation with data” really means. We’re looking forward to getting your feedback, and sharing our progress over the coming months and years.