Those designing data-driven products and services will know that it is often a challenging process; which comes with the burden of having to understand new and sometimes unclear requirements of privacy laws, including the General Data Protection Regulation (GDPR).

Drawing on the successful sandbox process developed by the FCA to understand and take a view on how regulation applies (or not, as the case may be) to the design of innovation products, the Information Commissioner's Office (ICO), which is responsible for enforcing GDPR and data protection in the UK, has launched an initial consultation, calling for evidence and initial views, on its proposed regulatory sandbox. The ICO is particularly interested in evidence based submissions provided by organisations that are developing innovative products and services which use personal data in innovative ways.

Potential benefits of the ICO regulatory sandbox include:

  • reducing regulatory uncertainty;
  • enabling more products to be brought to market; and
  • reducing the time of bringing those products to market,

while ensuring appropriate protections are in place.

It is important to note that whilst organisations will not be exempt from complying with data protection law, the ICO sandbox will enable organisations to develop innovative digital products and services in a collaborative manner, by giving organisations the opportunity to work with the ICO.

The deadline for responding to this initial consultation is 12 October 2018 and you can provide a response by visiting A detailed consultation is due later in the year.

If you have any questions or would like further information on the ICO regulatory sandbox please call us on 0161 941 4000 and ask for our Commercial department or email us at