ORG RESPONSE TO THE ICO CALL FOR VIEWS ON ENFORCEMENT PROCEDURAL GUIDANCE

TABLE OF CONTENTS

2.4. Do you have any comments on the alternative means we may use to resolve a matter other than opening an investigation? 2
Recommendations 4

2.5 Do you have any other comments on the section “How we decide whether to open an investigation”? 4
Recommendations: 6

3.1. Do you have any comments on the process to be followed when opening an investigation? 7
Recommendations: 8

3.3. Do you have any comments on our approach to engaging with controllers and processors during an investigation? 8
Recommendations: 8

4.1. Do you have any comments on our approach to the use of information notices and urgent information notices? 9
Recommendations: 10

4.2. Do you have any comments on our approach to the use of assessment notices and urgent assessment notices? 10
Recommendations: 11

4.3. Do you have any comments on our approach to requesting reports from approved persons as part of an assessment notice? 11
Recommendations: 11

6.1. Do you have any comments on our approach to closing investigations on the basis of our priorities, resolving the issues through other means, or there being no grounds for action? 12
Recommendations: 12

7.1. Do you have any comments on our approach to giving warnings? 13
Recommendations 13

8.1. Do you have any comments on our approach to giving reprimands? 13
Recommendations: 15

9.1. Do you have any comments on the factors we consider when deciding to give an enforcement notice or an urgent enforcement notice? 15
Recommendations: 16

11.2. Do you have any comments on the process for settlement discussions and concluding the case? 17
Recommendations: 17