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Empowering us to achieve great things together - our high-performance strategy

What is our high-performance strategy and who is it for?

We believe that a high-performance culture at the ICO is essential for our people and our customers. This strategy explains why and describes the high-performance culture we will then work together to achieve. It makes sure that we have a common understanding when we think and talk about our personal, team and organisational performance.

Our high-performance strategy guides the development of our culture, capability and capacity for the next five years, through to 2028. It reaches beyond our ICO25 strategy, supporting the implementation of our target operating model. We will define the detailed actions needed to deliver our high-performance culture through our yearly directorate, team and personal objectives and tools. The objectives in this strategy represent the cross-cutting and high-level activities we believe will take us towards our high-performance culture. This strategy therefore provides clarity and direction for all ICO employees and stakeholders about which work we are prioritising and why.

What does it mean for our people?

High performance is achievable for everyone at the ICO. It will be inclusive and accessible for all. This means our physical environment must work for everyone. Our technology must help us all to perform at our absolute best. Our working environment and approaches must continuously unlock the diverse perspectives and potential of our people. More broadly, we want everyone who shares our purpose and commits to our values and behaviours to feel included and that they belong at the ICO.

We need to enable and expect everyone to live our values and behaviours. Our values are:

  • curious;
  • collaborative;
  • impactful; and
  • inclusive.

What does it mean for our customers and stakeholders?

This strategy is also for our external customers and stakeholders. It explains what we are prioritising and doing to develop our high-performance culture. It enables them to hold us to account.

Our purpose

The purpose of the ICO’s high-performance strategy is to empower us to achieve great things together.

At the ICO, high performance means:

  • living our values and behaviours;
  • feeling empowered to be accountable and to continuously reflect and learn;
  • making an impact, both individually and collectively; and
  • providing great value for our customers.

To achieve this, we need to create the right environment and conditions for our people and services to thrive together. With this in place, we can all play our part to create and maintain our high-performance culture. This strategy explains how we are going to achieve this.

We will:

  • help our leaders and managers to create an inclusive environment for us all to learn and perform;
  • allow our corporate ‘enabling’ services to provide the right environment and tools for us all to achieve high performance; and
  • ensure every ICO employee understands what it means to be accountable for approaching our work and our relationships in ways which enhance our own performance and each other’s.

We know that, at the ICO, we have the greatest impact when we reach, understand and represent people and businesses in every corner of the society and economy we serve. Our commitment to equality, diversity and inclusion recognises that every ICO employee brings valuable experiences and ideas that are essential to achieving our high-performance culture.

Enabling our collective high performance requires a working environment based on high-quality:

  • office space;
  • systems;
  • processes; as well as
  • robust data and insight.

It also requires trusted leadership that encourages diversity of thought and perspective, as well as the right balance between collaborative and individual delivery of work.

We want to empower our people to work confidently and to make effective choices and decisions. This means creating the conditions for us all to feel comfortable to be accountable, supported to reflect openly and respectfully and able to learn continuously from our achievements and our setbacks. Having this psychological safety and candour in our relationships is therefore the foundation of our high-performance culture.


Our strategic context

We are on a continuous transformation journey. We recognise that to achieve our high-performance culture, we must consolidate our strengths and target efficiencies and investment in areas which most directly support our ICO25 shifts of approach. By doing this, we will reshape the ICO to achieve best value from our investment in our people, processes, systems and places. This also ensures value for money for the organisations and tax-payers funding our work.

Our work is varied, spans the UK economy and society and evolves at pace. This means we work with significant uncertainty with many different sectors throughout the UK and across 11 pieces of legislation. We need a diverse set of skills, experience and way of working to ensure we are delivering our purpose for our customers. This also means making difficult choices when prioritising the development of our capacity and capability and being specific about the culture we need to succeed.

We recognise that we need to, and our customers expect us to, deliver services in new and innovative ways. This is guided by our ICO25 shifts of approach. In particular, we must make greater use of digital and data- driven tools and services to provide the knowledge and insights to our customers and stakeholders as quickly as possible.

We must also enable our people to focus on the work that is most complex and impactful. We must continuously develop and use our knowledge and technical capability across the ICO to make this possible.

As a whole-economy regulator, there are almost endless risks and opportunities requiring our attention. We must develop our ability to make often difficult choices and deliver our objectives with agility.

We have grown as an organisation in recent years to meet the demands placed upon us. Whilst we may need some modest further growth, we must focus this growth in areas where we are unable to develop current capability or where we cannot meet new demand through improved productivity or by reprioritising our existing capacity.

This means we can expect to see a reshaping of the ICO during the life of this strategy. We expect this to mean focusing our growth in key areas, with consolidation and reprioritisation of capacity and capability in others.

For example, we expect to see growth in our digital data and technology, research and insight and legal professions during this strategy. We also expect to see a proportionate reduction in the size of our public-facing services over time. As we introduce more self-service opportunities for our customers, there will be opportunities for our people to focus on more complex and impactful work.

There is an increasingly competitive landscape for recruiting and retaining talented people. The future of work and employee motivations are changing rapidly in a post-pandemic labour market. Post-Covid, we now have a UK-wide workforce, utilising both our five office hubs and working from home as part of a truly hybrid approach to work. We know that there are increased expectations around what our technology and offices will deliver. Our ability to fairly reward our people for the work they do is also a priority under this strategy.


Our high-performance objectives

To achieve our high-performance culture, we have set ourselves seven cross-cutting objectives. They draw together the contributions needed from our leaders, enabling services and our people to develop and maintain our high-performance culture.

We will set our annual priorities against these objectives and measure and report our progress. We will use our business plans to develop specific operational action plans to deliver these objectives. These plans will have milestones and timescales, as well as performance measures to monitor our progress. This will ensure we are accountable for delivery.

Our high-performance objectives guide what we will do, as well as what we won’t do. It also shows how we will allocate our resources to support the delivery of each objective.

Objective one – To ensure that all ICO teams have clarity of purpose, effective leadership and harness diversity of thought and perspective to achieve their objectives.

We will do this by developing a culture that is diverse and inclusive to deliver in the best way possible.

We will provide support and tools to all teams which enable them to:

  • embed our values, shifts in approach and behaviours;
  • embed a common understanding of the principles of our high-performance culture to harness team strengths;
  • build the confidence and capability of all leaders and people managers to lead, develop and coach teams by adopting inclusive and adaptive leadership styles;
  • ensure our reward framework recognises our people for their contribution, impact and living our values, whilst maximising recruitment and retention of talent;
  • ensure that all our people feel psychologically safe to contribute openly to the work of the ICO. This includes understanding what it means to create psychological safety for others and being accountable for doing so;
  • embed a culture of respect and deliver our equality, diversity and inclusion objectives;
  • build on our supportive approach to make sure we are all well at work, providing our people with as much control as possible over where they work and the type of work they do; and
  • ensure our leaders build capacity in teams to deliver priorities with agility to support a healthy work and life balance.

Objective two – To continuously improve through experimentation, transforming the ICO to achieve our purpose whilst empowering our people to deliver and feel accountable in their roles.

We will do this by developing and implementing a clear, organisation-wide approach to prioritisation, supporting the agility of the ICO to change, transform and deliver.

We will provide support and tools which:

  • empower, support and expect our leaders to promote experimentation to drive continuous improvement through their people, using this approach as the basis for supporting people through strategic change;
  • embed project principles and approaches to the way we work to support agile and effective ways of working; and
  • encourage diverse views in our change initiatives, listening to one another as we make decisions on how we work and what we do whilst maintaining the important momentum behind our transformation.

Objective three – To plan and deploy our skills and resources with agility to meet the needs of our customers and stakeholders.

We will work clearly and flexibly, using workforce planning to ensure that we develop and use our skills and knowledge to deliver our priorities.

We will provide support and tools which:

  • ensure we have the right capabilities and professional skills at all levels of the ICO;
  • enable all teams to know the capability we have across the ICO and allow us to deploy our skills through the organisation quickly to anticipate and respond to demand;
  • deploy our workforce on demand, enabled by clear financial and workforce plans to inform succession and capability planning of teams;
  • ensure we focus on efficient use of our resources, prioritising customer experience and maximising outcomes;
  • increase our use of digital self-service channels to enable our customers to access our more routine or repetitive work as quickly as possible;
  • reshape the ICO and our teams through increased use of technology and automation, enabling our people to focus on the most complex and impactful work;
  • enhance people-based customer contact channels with knowledge and automation;
  • offer a joined-up (omnichannel) experience, whether human or digital; and
  • allow us to stop offering services via channels that underperform from a customer experience, efficiency or outcomes perspective.

Objective four – To make the ICO’s critical and most useful data and insights available while keeping our systems safe.

We will deliver data and technology that improves our efficiency and productivity, improving outcomes for our people and customers. We will maximise the ICO’s defences against both internal and external cyber threats and manage our information correctly.

We will:

  • be curious and led by data and evidence in the way we work;
  • use technology and data to enable our processes, improve our reporting and monitoring and provide efficient, customer-focused services to our colleagues and our stakeholders;
  • make our data available internally and externally via a single data platform, stopping unnecessary data silos. We'll prioritise data and capabilities based on use cases with the highest relative value. We'll also equip our people with data and analytical skills;
  • keep the ICO’s systems safe and secure by ensuring effective external horizon scanning to continually assess the threat landscape as well as implementing secure by design principles, ensuring cyber hygiene is adhered to and continually tested against best practices; and
  • ensure that, as a leading regulator, we manage all data appropriately by delivering proportionate information management best practices, assessments, policies, procedures and frameworks.

Objective five – To fund our highest priorities and ensure value for money.

We will demonstrate that our people and stakeholders understand how our funding is allocated to meet our priorities and how we deliver value for money.

We will:

  • allocate funding against the highest ICO priorities, enabling the flexing of our funding allocation to respond to changing needs and priorities, whilst ensuring we operate within our funding limits;
  • demonstrate value for money by having clear financial benefits realisation plans in place, ensuring that we measure, track and report the benefits and outcomes;
  • ensure that the ICO has a robust funding model in place to meet the longer-term needs of the organisation, through the structure of our fee income and grant-in-aid funding provision, and through longer-term financial scenario planning that supports our strategic workforce plan to aid strategic decision making; and
  • utilise procurement pipelines to improve planning, enabling the procurement function to proactively partner the business, delivering quality, value for money and compliant outcomes via efficient processes.

Objective six – To enable simple and transparent decision-making throughout the ICO, empowering through appropriate delegation and ensuring we can be held to account for our performance.

We will provide support and tools which:

  • ensure our decision-making approach is proportionate and transparent. This will mean greater individual ownership and responsibility for decisions, enabling us to move quickly, empowering our teams and leaders;
  • will focus on empowering personal control, accountability and responsibility and minimising unnecessary escalation when progressing our work, whilst maintaining collaborative decision-making;
  • embeds a proportionate risk-management framework to identify and manage risks and opportunities. This framework, and our clearly articulated risk appetite, will inform how we make decisions, enabling us to work in an agile way and at pace with a clear and consistent approach to how we prioritise our resources;
  • allows us to have a modern and agile governance structure which enables us to prioritise simply, quickly and transparently; and
  • enable us to report the impact and outcomes of our work, as well as the output, to allow our stakeholders to hold us to account.

Objective seven – To efficiently create a flexible and accessible work environment with compatible and integrated technology.

We will:

  • offer a modern hybrid experience that enables people to work and collaborate wherever they are;
  • enable our colleagues to improve their efficiency and productivity by enhancing our existing technology capability;
  • enable improvements in productivity and collaboration by having modern, flexible and accessible office accommodation that includes a range of workspaces with compatible, accessible and integrated technology;
  • promote innovation through the investment of new tools, systems and knowledge, to ensure the ongoing availability, performance and capacity of our technology estate;
  • anticipate a reduction in the footprint of our Wilmslow head office over time, have an appropriately scaled estates footprint across key UK locations and help our people to work where they are most productive; and
  • deliver against the government net zero strategy by developing a carbon management plan and sustainability policy, delivering these to achieve a reduction in our carbon footprint.



Everyone at the ICO has a responsibility to deliver the shifts of approach set out in ICO25. However, we have identified an accountable owner who is responsible for delivering the progress towards each of the high-performance objectives above. They will also report on our measures to demonstrate this progress. 


How we will know if we have achieved our objectives?

We invite our performance to be judged through measures.

Please see Appendix one - How we will know if we have achieved our objectives?