The ICO exists to empower you through information.

Information Commissioner’s foreword

In 2011 the ICO published its first Data Sharing Code; in the intervening period the type and amount of data collected by organisations has changed enormously, as has the technology used to store and share it, and even the purposes for which it is used. It is imperative that we keep up to date with these developments through this new code.

As the UK Information Commissioner, I know that data is one of modern society’s greatest assets. Ready access to information and knowledge, including about individual citizens, can lead to many economic and social benefits, including greater growth, technological innovations and the delivery of more efficient and targeted services.

We have written this Data Sharing Code to give individuals, businesses and organisations the confidence to share data in a fair, safe and transparent way in this changing landscape. This code will guide practitioners through the practical steps they need to take to share data while protecting people’s privacy. We hope to dispel many of the misunderstandings about data sharing along the way.

I have seen first-hand how proportionate, targeted data sharing delivered at pace between organisations in the public, private and voluntary sectors has been crucial to supporting and protecting the most vulnerable during the response to the COVID-19 pandemic. Be it through the shielding programme for vulnerable people, or sharing of health data in the Test and Trace system. On a local and national level, data sharing has been pivotal to fast, efficient and effective delivery of pandemic responses.

Utilising the data we collectively hold and allowing it to be maximised properly will have economic benefits. Data sharing that engenders trust in how personal data is being used is a driver of innovation, competition, economic growth and greater choice for consumers and citizens. This is also true in the sphere of public service delivery where efficient sharing of data can improve insights, outcomes and increase options for recipients.

This code demonstrates that the legal framework is an enabler to responsible data sharing and busts some of the myths that currently exist. But we cannot pretend that a code of practice is a panacea to solve all the challenges for data sharing. Or that targeted ICO engagement and advice will solve everything. There are other barriers to data sharing, including cultural, technical and organisational factors. Overcoming these will require more than just the ICO; it will require a collective effort from practitioners, government and the regulator.

I see the publication of this code not as a conclusion but as a milestone in this ongoing work. The ICO will continue to provide clarity and advice in how data can be shared in line with the law. This code, and the products and toolkits published alongside it, provides a gateway to good data sharing practice and the benefits we can expect from the results.


Elizabeth Denham CBE

Information Commissioner
May 2021