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Lessons from UK GDPR Fines: How Exception Oversight Could Help Avoid Them

The ICO has issued several high-profile fines under UK GDPR, often citing poor security practices, lack of accountability, and failure to protect personal data. Many of these cases could have been mitigated with better exception oversight in SMEs.

Common Themes in ICO Penalties

Recurring Compliance Failures

  • Unpatched systems left vulnerable.
  • Excessive employee access to sensitive records.
  • Inadequate response plans for data breaches.

How Exception Management Could Have Helped

1. Visibility

An exception register would have highlighted risks like unpatched systems and excessive access.

2. Accountability

Senior management approval of exceptions ensures risks are understood and accepted.

3. Time-bound Mitigation

Regular reviews prevent long-term non-compliance from becoming normal practice.

4. Evidence of Diligence

In case of investigation, documented exceptions show the SME took governance seriously.

Practical Steps for SMEs

Implementation Checklist

  • Establish a lightweight exception policy tied to GDPR compliance requirements.
  • Train staff to report potential exceptions (e.g., access beyond job role).
  • Review exceptions quarterly and link them to corrective action plans.

Outcome

Compliance Protection

By learning from past GDPR enforcement actions, SMEs can avoid the same mistakes. Exception oversight doesn't eliminate all risks, but it proves to the ICO that the business knew its gaps, managed them responsibly, and worked to fix them a critical difference between negligence and compliance.

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