On 26th July, Eversheds Sutherland reported that the UK Information Commissioner’s Office has launched a public consultation on its new draft data-sharing code of practice, with a consultation period that ends on 9th September.  It is an update of the previous code, to align it with GDPR so as to address transparency, lawful bases for processing, the new accountability principle and the requirement to record processing activities. It aims to give practical advice and guidance on how to share data safely and fairly: and the final code is due for launch this Autumn.  The vast majority of organisations share personal data in some way and this code focuses on sharing between data controllers.  It explains the law and provides examples of good practice, and following it will enable organisations to manage risks, clarify misconceptions, and share data in confidence.  The Code runs to 100+ pages, and the article provides a “speed read” of some key themes.


The draft Code is at –



This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at https://www.buymeacoffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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