No, there is not a high risk
As you’ve made an assessment that it is likely or very likely there will be a risk then you must notify the ICO.
However, as you have assessed there is not a high risk to individuals' rights and freedoms, there is no requirement to inform these individuals.
You may ring our Helpline for advice on how to manage the breach, mitigate the effect of the breach and to report the breach.
We’re usually open Monday to Friday from 9am until 5pm. If you need to report outside of these hours you should do so online.
Alternatively, if you are confident you are managing the effects of the breach and you don’t need advice, you can report details of the breach online.
You may want to take a screen shot of this page or use your browser to print the page so that you have a record of your assessment.
Return to the Report a breach page.