Handley Gill
LEGAL & REGULATORY COMPLIANCE CONSULTANTS

Handley Gill Limited

Our expert consultants at Handley Gill share their knowledge and advice on emerging data protection, privacy, content regulation, reputation management, cyber security, and information access issues in our blog.

Not so instant compliance
Not so instant compliance

As Meta announces the introduction of Instagram Teen Accounts for users in the UK, USA, Canada and Australia, Handley Gill’s specialist data protection and online trust and safety consultants consider the global laws and regulations that have spurred this change, and the role of the Information Commissioner’s Children’s Code aka the Age Appropriate Design Code, the UK Online Safety Act 2023, the US’ Kids Online Safety Act (‘KOSA’) and the Children and Teen’s Online Privacy Protection Act (‘COPPA 2.0’).

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Nicola CainOnline Safety, Online Harms, eSafety, Online Safety Act 2023, Data Protection, PERSONAL DATA, GDPR, General Data Protection Regulation, UK GDPR, UK GENERAL DATA PROTECTION REGULATION, DATA PROTECTION ACT 2018, Information Commissioner, Information Commissioner's Office, ICO, Children's Code, Age Appropriate Design Code, Social Media, Information Society Services, CHILDREN, Children's Data, Likely to be accessed by children, Trust and Safety, Privacy Settings, Meta, Instagram, Teen Accounts, KOSA, Kids Online Safety Act, Age Assurance, Age Verification, Enforcement, Data Protection Enforcement, Children and Teen’s Online Privacy Protection Act, COPPA, COPPA 2.0, Children's Code Strategy, ICO Children's Code Strategy, Protecting Children's Privacy Online, SMPs, Social Media Platforms, VSPs, Video Sharing Platforms, Platform Liability, Ofcom, Protecting Children from Harms Online, Children's Safety CodeComment
Another bauble for the tree?
Another bauble for the tree?

The UK government has today (05 September 2024) joined the US, EU and other countries in signing the Council of Europe’s Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law. Handley Gill’s specialist artificial intelligence (AI) consultants consider the implications of this statement of intent for the UK’s current and proposed legislation as announced in the King’s Speech 2024, and what new laws and amendments will be necessary to enable the UK to meet the AI Treaty’s obligations.

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Nicola CainArtificial Intelligence, AI, AI Regulation, AI Governance, Council of Europe Framework Convention on Artificial Intelligence and Human Rights Democracy and the Rule of Law, AI Treaty, Labour Party Manifesto 2024, King's Speech 2024, EU AI Act, Human Rights, Equality, Discrimination, Privacy, Data Protection, PERSONAL DATA, Human Rights Act 1998, Equality Act 2010, Data Protection & Digital Information Bill, Digital Information and Smart Data Bill, Democracy, Rule of Law, AI Systems, Online Safety Act 2023, Disinformatoin, Transparency, Liability, Redress, ICO, Information Commissioner, Equality and Human Rights Commission, Digital Regulation Co-operation Forum, DRCF, AI Regulation White Paper, Accuracy, Reliability, AI Safety, AI Security, Risk Management, AI Safety Institute, DisinformationComment
A problem shared...
A problem shared...

As Iceland boss Richard Walker decried data protection and human rights laws for allegedly preventing him and his staff from sharing information with other retailers in order tackle the scourge of shoplifting, Handley Gill’s specialist data protection consultants consider how these and other laws apply to retailers and shopping centre operators and identify the steps retailers can take to lawfully share personal data for the purposes of preventing or detecting crime.

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Nicola CainData Protection, Personal Data, GDPR, General Data Protection Regulation, Regulation (EU) 2016/679, UK GDPR, UK GENERAL DATA PROTECTION REGULATION, Data Controller, Data Sharing, Data Sharing Agreement, Criminal Conviction & Offence Data, Article 10 UK GDPR, Section 11 Data Protection Act 2018, s.11 DPA 2018, Section 11(2) Data Protection Act 2018, s.11(2) DPA 2018, Section 10 Data Protection Act 2018, S.10 DPA 2018, Section 10(5) Data Protection Act 2018, s.10(5) DPA 2018, Retail, Retail Crime, Theft, Shoplifting, Data Protection Offences, Data protection impact assessment, DPIA, Appropriate Policy Document, Schedule 1 Data Protection Act 2018, Public Domain, Manifestly Made Public, NT1 & NT2 v Google LLC [2018] EWHC 799 (QB), Data Privacy, Misuse of Private Information, Article 8 ECHR, Article 8 European Convention on Human Rights, Rehabilitation of Offenders Act 1974, Retention Schedule, Data Retention, Section 170 Data Protection Act 2018, Prevention or detection of crime, Crime prevention, Crime detection, Human Rights Act 1998, Reputation Management, Defamation, Libel, SlanderComment
Holiday packing list
Holiday packing list

With the summer holiday season in full swing, Handley Gill Limited’s specialist data protection and cyber resilience consultants consider the data protection and information security risks of staff taking data and devices used for business purposes overseas and the practical measures that organisations can take to safeguard data subject to border control powers.

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Nicola CainData Protection, PERSONAL DATA, UK GDPR, UK GENERAL DATA PROTECTION REGULATION, DATA PROTECTION ACT 2018, Cyber Security, Information Security, Data Controller, Data Processor, Overseas Travel, Data Transfer, Personal Data Transfer, Personal Data Export, Data Security, Border Control, Schedule 7 Terrorism Act 2000, Section 78(2) Customs and Excise Management Act 1979, Search, Seizure, Password protection, Encryption, Confidential Information, Confidentiality, Privacy, Digital PrivacyComment
A Herculean Labour?
A Herculean Labour?

Handley Gill’s specialist consultants consider what a Labour Party AI Bill, announced in the King’s Speech on 17 July 2024, will regulate, considering its manifesto commitments and the TUC’s proposed Artificial Intelligence (Employment and Regulation) Bill, and contrasting with Lord Holmes’ Artificial Intelligence (Regulation) Bill which fell at the dissolution of the last Parliament and the EU’s AI Act.

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Nicola CainAI, Artificial Intelligence, AI Regulation, AI Bill, Artificial Intelligence Bill, EU AI Act, Artificial Intelligence (Employment and Regulation) Bill, Workplace AI Risk Assessment, ESG, Equality Act 2010, Discrimination, Bias, AI Bias, Automated Decision Making, Article 22 UK GDPR, Article 22 GDPR, King's Speech 2024, Human Rights Act 1998, Human RightsComment
Off the rails?
Off the rails?

Handley Gill Limited’s specialist data protection and ESG consultants consider the results of the Information Commissioner’s Office’s Cyber Security Incident Trends Report for Q1 2024 and the implications for Sir Keir Starmer’s new Labour government, calling for a greater understanding of and focus on cyber and information risk management by directors and trustees.

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Nicola CainCyber Security, Data Protection, Cyber Security Breaches Survey 2024, Department for Science Innovation and Technology, Information Commissioner, Information Commissioner's Office, Cyber Attack, Data Breach, Data Breaches, Data Breach Statistics, Data Security Incident Trends Report, National Cyber Security Strategy 2022, Directors' Duties, ESGComment
A paradox of choice
A paradox of choice

Handley Gill Limited’s specialist consultants unpack the recent High Court decision in Harrison v (1) Cameron & (2) Alasdair Cameron Limited [2024] EWHC 1377 (KB), in which the High Court determined that data controllers responding to data subject access requests (DSARs) are obliged to disclose the specific identities of recipients of personal data, and are not permitted to merely disclose categories of recipient unless exceptions or exemptions apply.

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Nicola CainData Protection, PERSONAL DATA, UK GDPR, GDPR, General Data Protection Regulation, UK GENERAL DATA PROTECTION REGULATION, Article 15 UK GDPR, Article 15 GDPR, Data Subject Rights, DATA SUBJECT ACCESS REQUEST, DSAR, C-154/21, BREXIT, European Union (Withdrawal) Act 2018, Section 6 European Union (Withdrawal) Act 2018, S.6 European Union (Withdrawal) Act 2018, Austrian Post, C-154/21 RW v Osterreichische Post AG, Harrison v Cameron & Alasdair Cameron Limited [2024] EWHC 1377 KB, Data SharingComment
Security guaranteed?
Security guaranteed?

To coincide with London Tech Week 2024, one of the key themes of which is ‘The Future of Security and Data’, and following the revelation in the DSIT Cyber Security Breaches Survey 2024 that few organisations are conducting supply chain risk assessments, Handley Gill’s specialist consultants have published their Helping Hand checklist on conducting data processor / supply chain information security risk assessments which is informed by NCSC guidance.

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Nicola CainData Protection, Personal Data, UK GDPR, GDPR, General Data Protection Regulation, UK GENERAL DATA PROTECTION REGULATION, Information Security, Cyber Security, Information Security Risk Assessment, Cyber Security Risk Assessment, Cyber Attack, Cyber Incident, Data Breach, Data Controller, Data Processor, Article 28 UK GDPR, Article 28 GDPR, Article 28(1) UK GDPR, Article 28(1) GDPR, Cyber Security Breaches Survey 2024, Department for Science Innovation & Technology, National Cyber Security Centre, NCSC, Supply Chain Risk, Supply Chain Security, Vendor Management, Supplier Management, ICO, Information Commissioner, Information Commissioner's Office, Data Security Incident Trends Report, London Tech Week 2024, LTW, LTW 2024, The Future of Security and Data, Cyber Resilience, Online HarmsComment
Right my wrongs
Right my wrongs

As the Information Commissioner’s Office conducts the fourth part of its consultation on generative AI and data protection focusing on data subject rights, ‘engineering individual rights into generative AI models’, Handley Gill’s specialist data protection and artificial intelligence (AI) consultants comment on the issues arising and share their consultation response, as well as highlighting areas not currently addressed in the draft guidance.

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Nicola CainData Protection, PERSONAL DATA, Data Privacy, UK GDPR, GDPR, UK GENERAL DATA PROTECTION REGULATION, General Data Protection Regulation, Information Commissioner, Information Commissioner's Office, ICO, Data Subject Rights, SUBJECT ACCESS REQUEST, DATA SUBJECT ACCESS REQUEST, Data Subject Rights Request, Article 12 UK GDPR, ARTICLE 12(5) UK GDPR, Article 12 GDPR, Article 12(5) GDPR, Article 13 UK GDPR, Article 13 GDPR, Article 14 UK GDPR, Article 14 GDPR, Article 14(5)(b) UK GDPR, Article 14(5)(b) GDPR, Article 15 UK GDPR, Article 15 GDPR, Article 16 UK GDPR, Article 16 GDPR, Right to Rectification, Article 17 UK GDPR, Article 17 GDPR, Right to Erasure, Right to be Forgotten, RTBF, Article 18 UK GDPR, Article 18 GDPR, Right to restriction of processing, Article 19 UK GDPR, Article 19 GDPR, Consultation, Consultation Response, Artificial Intelligence, AI, Generative AI, Generative Artificial Intelligence, Web Scraping, AI Training, AI Training Data, AI Transparency, AI Regulation, Generative AI & Data Protection, Engineering Individual Rights into Generative AI Models, Privacy Notice, Privacy PolicyComment
Washed-up or fallen down the plughole?
Washed-up or fallen down the plughole?

Following the announcement on 22 May 2024 of the snap General Election to take place on 04 July 2024, Parliament has been prorogued with effect from 24 May 2024 (meaning Parliamentary business is suspended thereafter) and will be dissolved with effect from 30 May 2024. The brief period between the announcement of the election and prorogation is known as wash up, when political parties must negotiate to pass outstanding Bills, or parts of them, or Bills fall. Prorogation also bring an end to the work of the various Parliamentary Committees. Handley Gill’s consultants consider which Bills have been washed up and which have fallen in the context of cyber security, data protection, online safety, artificial intelligence (AI), digital markets, content regulation, reputation management, open justice, access to information, human rights and ESG, as well as the work of Parliamentary Committees which were either rushed out or dropped.

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Nicola CainGeneral Election 2024, GE2024, Data Protection, Personal Data, Data Protection and Digital Information Bill, Media Bill, Media Act 2024, Digital Markets Competition & Consumers Bill, Digital Markets Competition & Consumers Act 2024, Human Rights, Duty of Candour, Joint Committee on Human Rights, Education Committee, Commons Education Committee, Screentime impact on education & wellbeing, Science Innovation & Technology Committee, House of Commons Science Innovation & Technology Committee, Artificial Intelligence, AI, AI Governance, Governance of Artificial Intelligence, Artificial Intelligence (Regulation) Bill, SLAPPs, Strategic Litigation Against Public Participation Bill, Criminal Justice Bill, European Affairs Committee, UK-EU Data Adequacy, Adequacy Decision, Cyber Security, Information Security, Cyber Resilience, Cyber resilience of the UK's critical national infrastructure (CNI), Commons Women & Equalities Committee, Non-consensual intimate image abuse, Revenge porn, Online Safety, Online Harms, DPDI Bill, OFCOM, Competition and Markets Authority, CMA, Strategic Lawsuit Against Public Participation, Strategic Litigation Against Public Participation, Data Protection Reform, UK GDPR, Victims and Prisoners Act 2024, Article 17 UK GDPR, Article 17 GDPR, Right to Erasure, Right to be ForgottenComment
Time to regenerate
Time to regenerate

The Information Commissioner’s fourth call for evidence in its Generative AI consultation series on ‘engineering individual rights into generative AI models’ suggests that generative AI model developers should regenerate their privacy policies to ensure that they provide individuals with sufficient information to ascertain whether they have been affected by the web scraping of their personal data.

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Nicola CainData Protection, Personal Data, UK GDPR, UK GENERAL DATA PROTECTION REGULATION, Article 14 UK GDPR, Article 14(5)(c) UK GDPR, Artificial Intelligence, AI, AI Regulation, Generative AI, Generative Artificial Intelligence, Large Language Models, Web Scraping, Intellectual Property, Intellectual Property Rights, Copyright, Privacy Policy, Privacy Notice, GDPR, Article 14 GDPR, Article 14(5)(c) GDPR, Consultation, Information Commissioner, Information Commissioner's Office, ICO, PSED, Generative AI & Data Protection, Engineering Individual Rights Into Generative AI Models, Article 14(5)(b) UK GDPR, Article 14(5)(b) GDPRComment
Consigned to a watery grave
Consigned to a watery grave

The snap General Election announced by Prime Minister Rishi Sunak for 04 July 2024, and the consequent curtailment of the Parliamentary session, will mean that there will be insufficient time for the remaining Parliamentary stages of the Data Protection and Digital Information Bill, including the House of Lords Report stage which was due to commence from 10 June, to be undertaken prior to the prorogation and dissolution of Parliament.

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Nicola CainData Protection, Personal Data, UK GDPR, UK GENERAL DATA PROTECTION REGULATION, DATA PROTECTION ACT 2018, DPA 2018, Privacy and Electronic Communications (EC Directive) Regulations 2003, PECR, Data Protection and Digital Information (No. 2) Bill, Data Protection and Digital Information Bill, DPDI Bill, DPDI (No.2) Bill, DPDI2 Bill, Data Reform Bill, Data Protection ReformComment
Breach? Don’t preach! Take some good advice!
Breach? Don’t preach! Take some good advice!

Has a cyber incident got you in an awful mess and you don’t mean maybe? What if a data breach leaves you in trouble deep? From the hacker they warned you all about? You need some good advice… and an incident response plan!

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Nicola CainCyber Security, Information Security, Cyber Incident, Cyber Attack, Data Protection, Personal Data, UK GDPR, DATA PROTECTION ACT 2018, Article 33 UK GDPR, Article 34 UK GDPR, Article 33 GDPR, Article 34 GDPR, Incident Response Plan, Breach Response Plan, Data Breach, Data Breach Reporting, Data Breach Response, Information Commissioner, Information Commissioner's Office, Data Security Incident Trends Report, Cyber Security Breaches Survey 2024, Cyber Breaches Survey 2024, Cyber Insurance, Department for Science Innovation & Technology, DSITComment