Contain the incident, establish when the controller became aware, assess risk to people, and notify the ICO without undue delay and, where feasible, within 72 hours when Article 33 requires it.
Use this guide for implementation planning, not as a substitute for checking the consolidated UK GDPR, applicable Data Protection Act 2018 provisions, current ICO guidance, contracts, and the facts of the processing.
A UK GDPR breach workflow must distinguish a security incident from a , start the controller's awareness timeline, assess risk to people, and route three separate outcomes: ICO notification, communication to affected people, and the internal breach record. Every personal data breach must be documented, even when notification is not required.
Start when anyone reports loss, alteration, unauthorised disclosure or access, or loss of availability involving personal data. Contain the incident without destroying evidence. The controller is aware when it has a reasonable degree of certainty that a security incident has compromised personal data; record that timestamp and the facts supporting it.
Notify the ICO unless the breach is unlikely to result in a risk to people's rights and freedoms. The deadline is without undue delay and, where feasible, no later than 72 hours after awareness. If the facts are incomplete, submit the available Article 33 information and provide the rest in phases without undue further delay.
Apply the thresholds to the likely consequences for people, not only to the incident's technical severity or cost to the organisation. For example, ICO guidance says theft of a customer database that could enable identity fraud is likely to be reportable, while loss or inappropriate alteration of a staff telephone list would not normally require notification. These examples illustrate the test; the data, exposure, safeguards, affected people, and likely harm in the actual incident control the decision.
Run the Article 34 decision separately. A breach likely to create a high risk requires direct communication to affected people without undue delay. The message must describe the breach in clear language, give the DPO or other contact point, explain likely consequences and measures, and should give practical protection steps. Individual communication is not required where effective measures such as encryption made the data unintelligible, later measures removed the likely high risk, or direct contact would involve disproportionate effort and an equally effective public or similar communication is used.
Sources (4)
ICO guidance supports the breach workflow triage, reporting threshold, 72-hour notification, individual-notice, and breach-record steps.
ICO first-response guidance supports starting the timer, logging facts, containing the breach, assessing risk, and reporting early.
ICO self-assessment guidance supports the workflow decision on whether a breach is likely to risk people's rights and freedoms.
Binding definitions and duties for breach classification, processor escalation, ICO notification, affected-person communication, exceptions, phased reporting, and records.
The record should let a reviewer reconstruct what happened, when the controller became aware, which risk facts were known at each decision, and why the controller reported, did not report, or informed people.
Sources (3)
ICO guidance supports the breach workflow triage, reporting threshold, 72-hour notification, individual-notice, and breach-record steps.
ICO first-response guidance supports starting the timer, logging facts, containing the breach, assessing risk, and reporting early.
ICO self-assessment guidance supports the workflow decision on whether a breach is likely to risk people's rights and freedoms.
Review the workflow after each material incident and after changes to systems, processors, escalation contacts, the ICO reporting route, or regulator guidance. A post-incident review should test detection, awareness escalation, the risk method, evidence preservation, notification quality, and corrective actions.
Sources (3)
ICO guidance supports the breach workflow triage, reporting threshold, 72-hour notification, individual-notice, and breach-record steps.
ICO first-response guidance supports starting the timer, logging facts, containing the breach, assessing risk, and reporting early.
ICO self-assessment guidance supports the workflow decision on whether a breach is likely to risk people's rights and freedoms.
Assign incident triage, risk decisions, notifications, evidence, and corrective actions to named owners.
Create scoped breach questions, evidence fields, and review tasks.
Use Research Copilot to answer follow-up questions with cited source material.
Review scope, evidence, owners, and the next compliance actions with Sorena.
Decide whether a UK personal data breach must be reported to the ICO, when the 72-hour clock starts, what the report must contain, and when individuals must be told.
Use UK transfer approval regulations by checking the destination, recipient, data, sector, effective status, scope limits, and review evidence.
Current UK GDPR rules for significant solely automated decisions, meaningful human involvement, Article 22B restrictions, and Article 22C safeguards.
Apply the UK GDPR material and territorial scope tests to one processing activity, including exclusions, non-UK organisations, roles, and evidence.
Build UK GDPR Article 30 records for controller and processor activities, apply the narrow under-250 exception, and keep the records current and available to the ICO.
Decide whether a personal data breach must be reported to the ICO or communicated to individuals, with deadlines, exceptions, content, and evidence.
Apply UK GDPR children's protections and the Age Appropriate Design Code to online services likely to be accessed by children.
A practical guide to Children's Code scope, its 15 standards, age 13 consent, evidence, exceptions, and product implementation.
A verifiable UK GDPR checklist for scope, lawful processing, transparency, rights, governance, security, breaches, DPIAs, children, and transfers.
Answer common UK GDPR questions on scope, lawful basis, records, DPIAs, DPOs, rights, breaches, children, automated decisions, and international transfers.
Build a UK GDPR compliance programme around processing records, lawful decisions, rights operations, security, incidents, DPIAs, suppliers, and transfers.
Decide whether each party is a controller, joint controller, or processor under the UK GDPR, then record the role-specific duties, contract terms, and evidence.
Operate UK GDPR access, rectification, erasure, restriction, portability, objection, and automated-decision rights under the amended Article 12 timing rules.
Track UK GDPR deadlines for rights requests, privacy information, breach notification, DPIAs, and ICO prior consultation, with triggers and exceptions.
Screen UK GDPR processing for likely high risk, complete the required DPIA analysis before processing, reduce risk, and consult the ICO when high residual risk remains.
Decide when the UK GDPR requires a DPIA or DPO, what each must cover, when to consult the ICO, and what evidence to retain.
Run a UK subject-access workflow using the current Article 12A clock, reasonable identity and clarification steps, proportionate searches, exemptions, redactions, and response evidence.
Choose the UK IDTA or Addendum, complete the current Article 46 data protection test, add needed measures, and maintain evidence for restricted transfers.
Choose among the six familiar Article 6 bases and the UK's recognised legitimate interests basis, then document any Article 9 or 10 condition.
UK GDPR and PECR cookie guidance with practical consent, exemption, evidence, and cited implementation decisions.
Understand the UK GDPR £8.7 million or 2% and £17.5 million or 4% fine ceilings, which infringements fall into each band, and how the ICO sets a fine.
Map UK GDPR requirements by processing activity, role, lawful basis, data type, risk, rights, suppliers, automated decisions, and transfers.
Apply the UK GDPR restricted-transfer sequence: map the transfer, check Article 45A approval, choose an Article 46 safeguard and assessment, or justify a specific Article 49 derogation.
Decide whether a UK restricted transfer exists, whether adequacy applies, how to use the IDTA or UK Addendum, and how to document the data protection test.
See when to use the UK GDPR, when the Data Protection Act 2018 adds a condition or exemption, and which regime covers law enforcement or intelligence processing.
Determine whether UK GDPR, EU GDPR, or both apply, then separate representatives, regulators, transfer routes, national law, and post-Brexit UK amendments.
Choose between the UK IDTA and EU SCCs with the UK Addendum, complete the right documents, and record the separate UK and EU transfer assessments.
Compare current UK and EU rules for recognised legitimate interests, rights requests, access searches, automated decisions, and international transfers.
Configure separate UK and EU privacy operations for representatives, regulator contacts, rights requests, breach reporting, transfer tools, and evidence.
Choose and document the UK GDPR lawful basis that fits each processing purpose, including recognised legitimate interest, in force since 5 February 2026.
Decide whether an online service is likely to be accessed by UK children and apply the ICO Children's Code standards to product design and personal-data use.
Decide whether a personal data breach must be reported to the ICO, when the 72-hour clock starts, what the report needs, and when affected people must be told.
Check whether current UK adequacy regulations cover a restricted transfer, including partial coverage for Canada, Japan, and the US UK Extension.
Apply the current UK rules for significant solely automated decisions, special-category restrictions, meaningful human involvement, and Article 22C safeguards.
See which controllers and processors need records of processing activities, what each record must contain, and how the under-250-employee exemption works.
Decide whether each party is a controller, joint controller, processor, or sub-processor, then record the contracts, responsibilities, and evidence the role requires.
Screen for likely high-risk processing, complete the Article 35 assessment before processing, and consult the ICO if high residual risk remains.
Apply the three UK GDPR DPO triggers and document expertise, independence, reporting line, resources, tasks, contacts, and conflict controls.
Decide when to use the UK IDTA or Addendum, complete the Article 46 data protection test, add supplementary measures, and keep the transfer under review.
Apply the current UK PECR rules to cookies and similar technologies, including consent, five exceptions, UK GDPR overlap, and evidence.