ARTICLE
20 August 2025

ICO Publishes 2024 - 2025 Annual Report

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A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
On July 16 2025, the ICO published its annual report and financial statements for the period from April 1 2024 to March 31 2025 (the Report).
United Kingdom Privacy

On July 16 2025, the ICO published its annual report and financial statements for the period from April 1 2024 to March 31 2025 (the Report).

The Report sets out the ICO's operations undertaken in the 2024 - 25 financial year, as well as Parliamentary accountability reports and its financial statements. The Report summarises three key "causes" that it has focused on in the 2025-25 financial year:

  1. Children's privacy: The Report states that the ICO's work is currently focused on how social media and video sharing platforms use children's data, securing a raft of changes from platforms to ensure high privacy by default, that geolocation data is not used in ways that might put children at risk and that children are not targeted with personalised adverts. The ICO will continue to prioritise interventions to enforce the Children's Code;
  2. Artificial intelligence (AI) and biometrics: the ICO highlights the support it provided to organisations through its generative AI advice and regulatory sandbox, public consultation on generative AI and guidance on people's rights in the context of AI. The ICO plans to take this further by publishing its AI Code of Practice and engaging with key stakeholders on the use of AI and biometrics; and
  3. Online tracking: The Report attributes the ICO's online tracking strategy as key in promoting compliance to make online tracking fairer for organisations and data subjects, including by: (i) producing guidance; (ii) engaging with industry; (iii) scrutinising compliance; and (iv) taking investigatory and enforcement action. The Report notes that the ICO's online tracking strategy has prompted the UK's top 200 websites to give people genuine, equal choices when it comes to online tracking, and that the ICO will now focus on the UK's top 1,000 websites' compliance with data protection law.

The announcement is available here and the Report is available here.

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