What Recent Cyber Attacks Can Teach Us About Cyber Resilience

Cyber security incidents have become a regular feature of the news cycle.
From attacks on major retailers to breaches affecting public bodies and critical infrastructure, organisations of all sizes are facing increasing threats from cyber criminals. 

In Episode 4of the Guardians of Data podcast  Ibrahim Hasan spoke with Olu Odeniyi about cyber security through the lens of the recent cyberattacks on major UK retailers. They explored how businesses can build resilience and trust in the face of growing threats, the future of cyber security and practical tips for all of us to stay ahead of the hackers.  The following is an abridged transcript of the podcast: 

Cyber threats are becoming more sophisticated

Cyber criminals are constantly adapting their methods. While ransomware remains a major threat, organisations are also facing attacks involving artificial intelligence, supply chain vulnerabilities, compromised Internet of Things devices and even
state-sponsored actors.  

One of the most significant developments is the increasing use of AI by criminals. Generative AI can create convincing phishing emails, impersonate trusted individuals and help less skilled attackers launch sophisticated campaigns. In the past, poorly written emails were often a warning sign of fraud. Today, AI can produce polished and convincing communications that are much harder to identify as malicious. At the same time, defenders are using AI to improve detection, automate routine tasks and strengthen security monitoring.  

The growing risk of social engineering 

Many recent cyber attacks have not relied on advanced technical exploits.
Instead, attackers have targeted people. Social engineering remains one of the most effective methods of gaining access to systems. Criminals impersonate trusted individuals, helpdesk staff or suppliers to persuade employees to reveal information, reset passwords or approve access requests. 

The attack on Marks & Spencer reportedly involved attackers posing as IT support personnel to trick individuals into resetting credentials and disabling security controls. Once inside the network, attackers were able to move through systems and cause significant disruption. 

This highlights an important point. Technology alone cannot prevent cyber attacks. Security depends on people, processes and technology working together. 

Supply chain attacks are a growing concern

Modern organisations rely heavily on suppliers, contractors and service providers. While this brings efficiency and specialist expertise, it also creates additional cyber risk. Supply chain attacks occur when criminals compromise a third party in order to gain access to their target. Rather than attacking a large organisation directly, attackers often look for weaker points elsewhere in the supply chain. 

The recent retail attacks demonstrate how interconnected organisations have become. Even businesses with mature security programmes can be affected if a trusted supplier is compromised. This means organisations must look beyond their own systems and assess the security of the wider ecosystem they depend upon. 

Why resilience matters

One of the key themes from the discussion was resilience. No organisation can eliminate cyber risk completely. The question is not whether an attack will occur, but how well prepared an organisation is to respond. 

The Co-op’s response to a recent attack illustrates this point. Having experienced previous incidents, the organisation had invested in preparation and incident response planning. This enabled it to detect suspicious activity quickly and take action to limit the damage. 

Early detection is critical. The sooner an attack is identified, the sooner organisations can activate response plans and contain the threat. Cyber resilience means understanding risks, preparing for incidents and ensuring the business can continue operating when problems occur.

Multi-factor authentication is essential but not enough

Multi-factor authentication (MFA) remains one of the most effective security controls available. However, not all forms of MFA provide the same level of protection. 
Many organisations rely on simple push notifications sent to mobile devices.
Attackers have learned how to exploit this through what is known as MFA fatigue.
In these attacks, criminals repeatedly trigger authentication requests in the hope that a user will eventually approve one by mistake. 

Organisations should therefore consider stronger authentication methods, particularly for privileged accounts. Hardware security keys and passkeys offer significantly greater protection and are more resistant to phishing attacks. 

Security controls should be based on risk, with the strongest protections applied to accounts that could cause the most damage if compromised. 

Privileged accounts remain a prime target

Attackers often focus on obtaining privileged or administrator-level access. 
Once criminals gain control of these accounts, they can access sensitive information, disable security tools and move freely through systems. This was highlighted in the discussion of recent retail breaches, where attackers reportedly sought to obtain elevated access after gaining an initial foothold. 

Organisations should ensure privileged access is tightly controlled, regularly reviewed and granted only when necessary. The principle of least privilege remains one of the most effective ways of reducing risk. 

Observability and monitoring are becoming critical

A recurring challenge in cyber security is that many organisations do not realise they have been compromised until weeks or even months after the initial breach. During that time, attackers can explore systems, steal information and establish persistence. Improved monitoring and observability can help organisation identify unusual behaviour more quickly. Understanding what normal activity looks like makes it easier to spot anomalies that could indicate an attack. The ability to detect threats early can significantly reduce the impact of an incident. 

What can individuals do?

Cyber security is not solely an organisational responsibility. Individuals also play an important role in protecting their personal information. Some practical steps include: 

* Using strong and unique passwords for every account. 

* Using a password manager to store credentials securely. 

* Enabling multi-factor authentication wherever possible. 

* Using passkeys where supported. 

* Avoiding the reuse of passwords across different services. 

* Being cautious about the information shared online. 

* Monitoring accounts following any reported data breach. 

Criminals frequently combine information gathered from different sources to make scams appear more convincing. Limiting the amount of personal information available online can reduce this risk. 

The recent wave of cyber-attacks offers several important lessons: 

1. Treat cyber security as a board-level responsibility. 

2. Strengthen supply chain security and vendor oversight. 

3. Invest in incident response planning and regular testing. 

4. Adopt stronger forms of multi-factor authentication. 

5. Limit privileged access and apply the principle of least privilege. 

6. Improve monitoring and threat detection capabilities. 

7. Provide regular staff awareness training focused on social engineering. 

8. Build resilience so the organisation can continue operating during an incident. 

The cyber threat landscape is unlikely to become simpler. The combination of increasing digitalisation, AI-driven attacks, global interconnectivity and geopolitical tensions means organisations will continue to face growing challenges. At the same time, regulation and governance requirements are likely to increase as governments seek to improve cyber resilience across both the public and private sectors. The organisations that succeed will be those that treat cyber security as a business issue rather than simply an IT issue. 

Listen to the full Episode 4with Olu.  

Previous episodes of the Guardians of Data podcast have featured Jen Persson, a privacy campaigner, explaining the privacy implications of the Government’s new plans for children’s data and Tahir Latif discussing how to build responsible and ethical AI systems.

Act Now Wins IRMS Supplier of the Year Award 2026

Act Now Training is proud to announce that it has won the Information and Records Management Society (IRMS) Supplier of the Year award for 2026. The aim of the award is “to recognise suppliers in the IG/IM/RM world that go above and beyond normal expectations of customer service.”  The awards ceremony took place on Monday night at the IRMS Conference in Cardiff. 

This is the fourth time in six years that Act Now Training has won this award. Ibrahim Hasan said:  

“We would like to thank all our colleagues in the IG profession who voted for us. 
The award recognises our education led approach and our commitment to providing measurable training that develops participants’ IG skills, competencies and behaviours.   

It has been another fantastic 12 months for Act Now Training. Notable achievements include: 

Launching the Guardians of Data Podcast 

The new Guardians of Data Podcast has proved extremely popular with the IG profession. It’s a show which explores the world of information law and information governance; from privacy and AI to cybersecurity and freedom of information. In each episode we speak to experts and practitioners to unpack the big issues shaping the IG profession 

Previous episodes  have featured Tahir Latif talking about responsible AI deployment, Naomi Matthews and Ibrahim Hasan  explaining the law on filming people in public for social media, Maurice Frenkel looking back at 20 years of the Freedom of Information Act and Olu Odeniyi analysing recent cyber breaches and discussing the lessons learnt. 

Building the AI Skillset  

Act Now launched the AI Governance Practitioner Certificate with the aim of helping data protection professionals to play a leading role in addressing the legal and ethical dilemmas posed by emerging AI as well as position themselves as
forward-thinking leaders who can bridge the gap between law, ethics, and technology. The course has been extremely well received by the profession.     

Revising the Advanced GDPR certificate  

Since its launch in 2020, Act Now’s  Advanced Certificate in GDPR Practice has attracted hundreds of DPOs from across the public and private sectors. Feedback has been consistently positive with many participants commenting on how the course has given them the confidence and skills to be able to dissect complex data protection scenarios and give clear and practical compliance advice. This year the syllabus has been revised to reflect advances in technology, especially in AI, and the latest ICO/Tribunal decisions. The assessment method for this course has also been revised to help develop participants’ communication skills. 

Delivering New Workshops  

Act Now has continued to provide relevant and cost effective IG workshops during rapidly changing times for the IG community. Our programme has been expanded to include practical advice on topical issues such as the Data (Use and Access) Act, Data Breach Management and Children’s Data. 

New Podcast: Lessons from Cyber Breaches

Act Now is pleased to bring you episode 4 of the Guardians of Data podcast. This is a show where we explore the world of information law and information governance; from privacy and AI to cybersecurity and freedom of information.  

The topic of this episode is cyber security. Every week we read about organisations being hacked, held to ransom or their data being stolen. The BBC recently discovered, through an FOI request, that around 10 million people had their data stolen when Transport for London (TfL) was hacked in 2024, making it one of the biggest hacks in British history. The so-called Scattered Spider crime group, breached TfL’s internal computer systems, disrupting its online services and causing £39m of damage. 

And the breakout of war in the Middle East has significantly increased the risk of cyber-attack. The National Cyber Security Centre (NCSC) recently warned that organisations should prepare for the risk of collateral damage from Iran-linked hacktivists. It said those with a presence in the region should consider boosting the monitoring of their IT systems and follow the centre’s guidelines for dealing with a heightened threat of cyber-attacks. 

In this podcast we talk about cyber security through the lens of the recent cyberattacks on major UK retailers. In just the past few months, household names like, Jaguar Land Rover, Gucci, Marks & Spencer and Co-op have suffered significant disruption from ransomware attacks and other cyber incidents. These caused empty shelves, disrupted online orders and shook customer trust. 

To help us unpack what happened and what lessons we can all take away, we are joined by Olu Odeniyi a Cyber Security expert and trusted advisor with more than 30 years’ experience in this field. In our conversation, we also explore how businesses can build resilience and trust in the face of growing threats, the future of cybersecurity and practical tips for all of us to stay ahead of the hackers.  

Download and listen here, or on your preferred podcast app. 
Available on Apple Podcasts, Spotify, and all major podcast platforms. 

Previous episodes of the Guardians of Data podcast have featured Jon Baines, talking about his career as a Data Protection specialist and the hot issues in information governance, and Lynn Wyeth discussing the recent controversy around Grok AI and Maurice Frenkel talking about 20 years of the Freedom of Information Act.

Cyber Security and Resilience Bill in Parliament 

On 12th November 2025, the Government introduced the Cyber Security and Resilience (Network and Information Systems) Bill in the House of Commons. This is an important development in the evolution of the UK’s cyber security regulation. The Bill is currently at the Committee stage.

The Bill was trailed in the King’s Speech of July 2024, and was followed by the Government publishing its Cyber security and resilience policy statement. The Bill is designed to update the existing Network and Information Systems Regulations 2018 to raise cyber resilience across key parts of the economy, and to give government and regulators more agile powers to respond to evolving threats. Amongst other things, it will expand cyber security regulation to cover more digital services and supply chains, and mandate increased incident reporting to improve the government’s response to cyber-attacks including where a company has been held to ransom. 

The Bill imposes new maximum penalties similar to GDPR levels. For more serious breaches, the maximum penalty is up to £17 million, or 4% of a regulated entity’s worldwide turnover, whichever is higher. For other breaches, the maximum penalty is up to £10 million, or 2% of a regulated entity’s worldwide turnover, whichever is higher. 

Key Provisions 

Expanded Regulatory Scope: The Bill will broaden the range of organisations and sectors under regulatory oversight, extending beyond essential services and digital providers to include a wider array of entities integral to national infrastructure. ​ 

Enhanced Regulatory Powers: Regulators will receive increased authority to ensure compliance with cybersecurity standards, including proactive investigation capabilities and mechanisms for cost recovery to support their activities. ​ 

Mandatory Incident Reporting: The Bill mandates comprehensive reporting of cyber incidents, notably ransomware attacks, to improve national threat assessment and response strategies. ​ 

Supply Chain Security: The Bill introduces measures to strengthen supply chain security, granting regulators the power to designate ‘Critical Suppliers’ whose services are integral to public sector operations. ​ 

Regulatory Oversight: The Information Commissioner’s Office will gain greater authority to investigate and enforce compliance among digital service providers, including those that supply technology to the public sector. ​ The ICO recently published its response to the Bill. 

For a detailed analysis of the Bill, read this article by law firm Clifford Chance. 

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security. See also our Managing Personal Data Breaches Workshop.

Our 23rd Birthday! Celebrate with Us and Save on Training  

This month marks 23 years of Act Now Training. We delivered our first course in 2003 (on the Data Protection Act 1998!) at the National Railway Museum in York. Fast forward to today, and we deliver over 300 training days a year on AI, GDPR, records management, surveillance law and cyber security; supporting delegates across multiple jurisdictions including the Middle East.  

Our success comes from more than just longevity; we are trusted by clients across every sector, giving us a unique insight into the real-world challenges of information governance. That’s why our education-first approach focuses on practical skills, measurable impact, and lasting value for your organisation. 

Anniversary Offer: To celebrate, we are giving you a £50 discount on any one-day workshop, if you book by 30th September 2025. Choose from our most popular sessions like GDPR and FOI A to Z, or explore new topics like AI and Information Governance and the Risk Managment in IG

Simply quote “23rd Anniversary” on your booking form to claim your discount.

The MoD Afghan Data Breach: Could the Information Commissioner have done more? 

On Tuesday, the High Court lifted a superinjunction that prevented scrutiny of one of the most serious personal data breaches involving a UK Government department. In February 2022, a Ministry of Defence (MoD) official mistakenly emailed a spreadsheet containing personal details of over 18,000 Afghan nationals who had applied to move to the UK under the Afghan Relocations and Assistance Policy (ARAP).  

The breach was only discovered in August 2023, when excerpts of the data appeared on Facebook. By then, the damage was done. A new resettlement scheme for those on the leaked list was set up and has seen 4,500 Afghans arrive in the UK so far. The Afghan Relocation Route has cost £400m so far, and the Government has said it is expected to cost a further £450m. Interesting that that the High Court in May 2024 heard it could cost “several billions”. 

Shockingly, people whose details were leaked were only informed on Tuesday. A review of the incident carried out on behalf of the MoD found it was “highly unlikely” an individual would have been targeted solely because of the leaked data, which “may not have spread nearly as widely as initially feared”. On Wednesday though, the Defence Secretary said he was “unable to say for sure” whether anyone had been killed as a result of the data breach. The daughter of an Afghan translator whose details were leaked told the BBC that her whole family “panicked”.  

“No one knows where the data has been sent to – it could be sent to the Taliban, they could have their hands on it,” she said. Her grandmother, who is still in Afghanistan, is “completely vulnerable”, she added. 

This is not the first time the MoD has mishandled Afghan data. In December 2023, it was fined £350,000  for disclosing details of people seeking relocation to the UK shortly after the Taliban took control of Afghanistan in 2021. The MoD sent an email to a distribution list of Afghan nationals eligible for evacuation using the ‘To’ field, with personal information relating to 245 people being inadvertently disclosed. The email addresses could be seen by all recipients, with 55 people having thumbnail pictures on their email profiles.  
Two people ‘replied all’ to the entire list of recipients, with one of them providing their location.  

ICO’s Response 

Despite the scale and sensitivity of the latest MoD data breach, the Information Commissioner’s Office (ICO) has decided not to take any regulatory action; no, not even a reprimand! In its press release, the ICO praised the MoD’s internal investigation and mitigation efforts, stating that “no further regulatory action is required at this time”. 

Compare this case to the data breach involving the Police Service of Northern Ireland (PSNI). Last year, the ICO fined the PSNI £750,000 after staff mistakenly divulged the surnames of more than 9,483 PSNI officers and staff, their initials and other data in response to a Freedom of Information (FoI) request. The request, via the What Do They Know.Com website, had asked the PSNI for a breakdown of all staff rank and grades. But as well as publishing a table containing the number of people holding positions such as constable, a spreadsheet was included. The information was published on the WDTK website for more than two hours, leaving many fearing for their safety. 

In September las year it was announced that a mediation process involving the PSNI is to take place to attempt to agree the amount of damages to be paid to up to 7,000 staff impacted by the data breach. The final bill could be as much as £240m, according to previous reports. Compare that with the impact and cost of the latest MoD data breach. 

Other ICO enforcement actions in the past few years for security failures include: 

  • Cabinet Office (2020): Fined £500,000 for publishing New Year Honours list online. Cause? Spreadsheet error. 
  • HIV Scotland (2021): Fined £10,000 when it sent an email to 105 people living with HIV. All the email addresses were visible to all recipients, and 65 of the addresses identified people by name. From the personal data disclosed, an assumption could be made about individuals’ HIV status or risk.   
  • Mermaids (2021): Fined £25,000 for failing to implement an appropriate level of security to its internal email systems, which resulted in documents or emails containing personal data being searchable and viewable online by third parties through internet search engine results.  

In the MoD case, the ICO claims it considered the “critical need to share data urgently” and the MoD’s “steps to protect those most affected”. But urgency wasn’t the issue; it was negligence. The breach occurred during routine verification, not a crisis. Even more concerning, the ICO’s own guidance states that breaches involving unauthorised disclosure of sensitive data, especially where lives are at risk, should trigger enforcement action. 

This lack of action by the ICO raises serious questions about the ICO’s independence and willingness to challenge government departments. Even if it felt a fine was not appropriate, a report to Parliament (under Section 139(3) of Data Protection Act 2018) would have highlighted the seriousness of the issues raised and consequently allowed MP’s to scrutinise the MoD’s actions.  

This breach is a national scandal; not just for its scale, but for the lack of transparency, accountability, and regulatory action. If the UK is serious about data protection, it must demand more from its regulator. Otherwise, the next breach may be even worse and just as quietly buried. 

Yesterday, the Commons Defence Committee confirmed it would launch its own inquiry, and Dame Chi Onwurah, chair of the Commons Committee for Science Innovation and Technology, said that it is writing to the Information Commissioner pushing for an investigation. Watch this space! 

STOP PRESS: This afternoon the BBC reports that the data breach was much worse than previously thought: it contained personal details of more than 100 British officials including those whose identities are most closely guarded – special forces and spies. Is an ICO u turn incoming?

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security.

£2.31 Million GDPR Fine for Genetic Testing Company. But will the fine be paid? 

The Information Commissioner’s Office (ICO) has fined a US genetic testing company £2.31 million under the UK GDPR following a 2023 cyber-attack. 

23andMe provides genetic testing for, amongst other things, health purposes and ancestry tracing. In 2023 a hacker carried out a credential stuffing attack on the company’s platform, exploiting reused login credentials that were stolen from previous unrelated data breaches. This resulted in unauthorised access to 155,592 UK residents’ personal data; potentially revealing sensitive data such as profile images, race, ethnicity, family trees and health reports. The type and amount of personal data accessed varied depending on the information included in a customer’s account. 

The investigation into 23andMe revealed serious security failings at the time of the 2023 data breach. The company failed to implement appropriate authentication and verification measures, such as mandatory multi-factor authentication, secure password protocols, or unpredictable usernames. It also failed to implement appropriate controls over access to raw genetic data and did not have effective systems in place to monitor, detect, or respond to cyber threats targeting its customers’ sensitive information. 

The ICO also found that 23andMe’s response to the unfolding incident was inadequate. The hacker began their credential stuffing attack in April 2023, before carrying out their first period of intense credential stuffing activity in May 2023.
In August 2023, a claim of data theft affecting over 10 million users was dismissed as a hoax, despite 23andMe having conducted isolated investigations into unauthorised activity on its platform in July 2023. Another wave of credential stuffing followed in September 2023, but the company did not start a full investigation until October 2023, when a 23andMe employee discovered that the stolen data had been advertised for sale on Reddit. Only then did 23andMe confirm that a breach had occurred.  

What happens now? 

The ICO has made much of this penalty and the joint investigation conducted with the Office of the Privacy Commissioner of Canada. John Edwards, the Information Commissioner, said: 

“We carried out this investigation in collaboration with our Canadian counterparts, and it highlights the power of international cooperation in holding global companies to account. Data protection doesn’t stop at borders, and neither do we when it comes to protecting the rights of UK residents.” 

The fine comes after an ICO statement in March which said that a Notice of Intent had been issued of £4.59 million. An almost 50% reduction but, whatever the amount of the fine, the ICO is unlike to see a penny.  

In April 23andMe filed for bankruptcy in the US courts. On Friday it said that it had agreed to the sale of its assets to a non-profit biotech organisation led by its
co-founder and former chief executive. It said the purchase of the company would come with binding commitments to uphold existing policies and consumer protections, such as letting customers delete their accounts, genetic data and opt out of research.
A bankruptcy court is scheduled to hear the case for its approval on Wednesday. 

This case is also a good example of  the extra territorial reach of the UK GDPR.  Article 3(2)(a) UK GDPR as although 23andMe is not established within the UK, it processes the personal data of the affected UK Data Subjects for the purposes of offering goods or services to those individuals. 

This is the third fine issued by the ICO in 2025. In April a £60,000 fine was issued to a law firm and in March an NHS IT supplier was fined £3million. Both also followed cyber-attacks.   

 We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to up skill their employees about cyber security. See also our Managing Personal Data Breaches Workshop. 

What is the Role of IG Professionals in AI Governance? 

The rapid rise of AI deployment in the workplace brings a host of legal and ethical challenges. AI governance is essential to addresses these challenges and ensuring AI systems are transparent, accountable, and aligned with organisational values. 

AI governance requires a multidisciplinary approach involving, amongst others, IT, legal, compliance and industry specialists. IG professionals also possess a unique skill set that makes them key stakeholders in the governance process. Here’s why they should actively position themselves to play a key role in AI governance within their organisations. 

AI Governance is Fundamentally a Data Governance Issue 

At its core, AI is a data-driven technology. The fairness and reliability of AI models depend on the quality, accuracy, and management of data. If AI systems are trained on poor-quality or biased data, they can produce flawed and discriminatory outcomes. (See Amnesty International’s report into police data and algorithms.)  

IG professionals specialise in ensuring that data is accurate, well-structured, and fit for purpose. Without strong data governance, organisations risk deploying AI systems that amplify biases, make inaccurate predictions, or fail to comply with regulatory requirements. 

Regulatory and Compliance Expertise is Critical 

AI governance is increasingly being shaped by regulatory frameworks around the world. The EU AI Act and regulations and guidance from other jurisdictions highlight the growing emphasis on AI accountability, transparency, and risk management. 

IG professionals have expertise in interpreting legislation (such as GDPR, PECR and DPA amongst others) which positions them to help organisations navigate the complex legal landscape surrounding AI. They can ensure that AI governance frameworks comply with data protection principles, consumer rights, and ethical AI standards, reducing the risk of legal penalties and reputational damage. 

Managing AI Risks and Ensuring Ethical AI Practices 

AI introduces new risks, including algorithmic bias, privacy violations, security vulnerabilities, and explainability challenges. Left unchecked, these risks can undermine trust in AI and expose organisations to significant operational and reputational harm. 

IG Governance professionals excel in risk management (After all, that is what DPIAs are about). They are trained to assess and mitigate risks related to data security, data integrity, and compliance, which directly translates to AI governance. By working alongside IT and ethics teams, they can help establish clear policies, accountability structures, and risk assessment frameworks to ensure AI is deployed responsibly. 

Bridging the Gap Between IT, Legal, and Business Functions 

One of the biggest challenges in AI governance is the lack of alignment between different business functions. AI development is often led by technical teams, while compliance and risk management sit with legal and governance teams. Without effective collaboration, governance efforts can become fragmented or ineffective. 

IG professionals act as natural bridges between these groups. Their work already involves coordinating across departments to align data policies, privacy standards, and regulatory requirements. By taking an active role in AI governance, they can ensure cross-functional collaboration, helping organisations balance innovation with compliance. 

Addressing Data Privacy and Security Concerns 

AI often processes vast amounts of sensitive personal data, making privacy and security critical concerns. Organisations must ensure that AI systems comply with data protection laws, implement robust security measures, and uphold individuals’ rights over their data. 

IG and Data Governance professionals are well-versed in data privacy principles, data minimisation, encryption, and access controls. Their expertise is essential in ensuring that AI systems are designed and deployed with privacy-by-design principles, reducing the risk of data breaches and regulatory violations. 

AI Governance Should Fit Within Existing Frameworks 

Organisations already have established governance structures for data management, records retention, compliance, and security. Instead of treating AI governance as an entirely new function, it should be integrated into existing governance models. 

IG and Data Governance professionals are skilled at implementing governance frameworks, policies, and best practices. Their experience can help ensure that AI governance is scalable, sustainable, and aligned with the organisation’s broader data governance strategy. 

Proactive Involvement Prevents Being Left Behind 

If IG professionals do not step up, AI governance may be driven solely by IT, data science, or business teams. While these functions bring valuable expertise, they may overlook regulatory, ethical, and risk considerations. Fundamentally, as IG professionals, our goal is to ensure organisations are using data and any new technology responsibly. 

So we are not saying that IG and DP professionals should become the new AI overlords. But by proactively positioning themselves as key stakeholders in AI governance, IG and Data Governance professionals ensure that organisations take a holistic approach – one that balances innovation, compliance, and risk management. Waiting to be invited to the AI governance conversation risks being sidelined in decisions that will have long-term implications for data governance and organisational risk. 

Final Thoughts 

To reiterate, AI governance should not be the sole responsibility of IG and Data Governance professionals – it requires a collaborative, cross-functional approach. However, their expertise in data integrity, privacy, compliance, and risk management makes them essential players in the AI governance ecosystem. 

As organisations increasingly rely on AI-driven decision-making, IG and Data Governance professionals must ensure that these systems are accountable, transparent, and legally compliant. By stepping up now, they can shape the future of AI governance within their organisations and safeguard them from regulatory, ethical, and operational pitfalls. 

Our new six module AI Governance Practitioner Certificate will empower you to understand AI’s potential, address its challenges, and harness its power responsibly for the public benefit.  

ICO Issues £60,000 GDPR Fine  

The Information Commissioner’s Office (ICO) has fined a Merseyside-based law firm £60,000 following a cyber-attack that led to highly sensitive personal data being published on the dark web. 

DPP Law Ltd (DPP) specialises in a number of areas of law including crime and actions against the police. It suffered the cyber-attack in June 2022 which affected access to the firm’s IT systems for over a week. The hackers were able to move laterally across DPP’s network and take over 32GB of data. DPP only became aware of this after the National Crime Agency contacted the firm to advise information relating to their clients had been posted on the dark web. DPP did not report the incident to the ICO until 43 days after they became aware of it. 

The ICO found that DPP failed to put appropriate measures in place to ensure the security of personal data held electronically. This failure enabled the hackers to gain access to DPP’s network, via an infrequently used administrator account which lacked multi-factor authentication (MFA) and steal large volumes of data. 

This is the second GDPR fine issued to a law firm. In March 2022, the ICO issued a fine of £98,000 to Tuckers Solicitors LLP. The fine followed a ransomware attack on the firm’s IT systems in August 2020. The attacker encrypted 972,191 files, of which 24,712 related to court bundles. 60 of those were exfiltrated by the attacker and released on the dark web. 

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security. See also our Managing Personal Data Breaches Workshop

Supporting Careers in Data Protection Through Apprenticeships 

In today’s digital landscape, data protection and information governance have become critical risk areas for organisations across all sectors. With increasing regulatory demands and evolving threats, the need for skilled professionals in this field has never been greater. Recognising this growing skills gap, Damar Training, with the support of Act Now Training,  launched its innovative Data Protection and Information Governance Apprenticeship programme in late 2022, quickly establishing itself as the leading provider in England.

The programme was developed through extensive consultation with employers, including members of the apprenticeship Trailblazer Group, to ensure it would be commercially attractive, impactful, and of the highest quality. This collaborative approach has led to excellent engagement from employers and individuals, with 243 apprentices starting the programme to date, making Damar the largest provider of this apprenticeship standard in England.

A Flexible, Comprehensive Learning Journey

What sets Damar’s apprenticeship apart is its thoughtfully designed modular structure, with carefully sequenced six-week blocks of learning that cater to diverse learning styles and organisational needs. The gradual layering of technical content and learning activity, designed with the assistance of Act Now Training, ensure that apprentices from both public and private sectors receive an outstanding foundation in the knowledge, skills, and behaviours required for success in data protection roles.

The delivery model combines self-directed learning through engaging online resources with regular one-to-one coaching visits and group coaching sessions.
Extended technical workshops (underpinned by Act Now’s expertise) and quarterly review meetings provide additional support, while dedicated forums allow apprentices to stay updated with the latest developments, engage with peers, and consult with coaches.

This comprehensive approach has yielded impressive results. With a retention rate of 68%, an achievement rate of 65%, and an EPA pass rate of 95% – all above national averages – the programme demonstrates exceptional quality, particularly remarkable for a relatively new offering.

Industry-Leading Expertise

A key strength of Damar’s apprenticeship is its partnership with Act Now, an
award-winning data protection consultancy. This collaboration ensures that the programme’s content remains at the cutting edge of industry developments, including emerging areas such as Artificial Intelligence regulation.

Sarah Murray, Data Protection Officer at ClearData, highlights this benefit: 

“One of the particular stand-outs for me is the workshops. With the content supported by
Act Now, who have such a good reputation in this field, the workshops really put all of the theory into real-life practice.”

Real-World Impact for Employers and Apprentices

The programme serves some of the UK’s major employers, including Heathrow Airport, National Express, the BBC, Auto Trader, Betfred, and Dunelm, alongside various NHS Trusts, universities, government departments, and local councils.

For apprentices, the transformation goes beyond technical knowledge. Many begin with only basic data protection skills and limited confidence. Through the programme, they develop not only technical expertise but also a deeper understanding of the “why” behind data protection practices and the confidence to advise others with authority.

This growth translates into tangible career progression, with 99% of apprentices experiencing positive outcomes – 53% remaining in their current roles with enhanced skills, 18% securing permanent positions, and 28% gaining promotions or additional responsibilities. Some have even become data protection officers with overall responsibility for their organisation’s data protection function.

Employers benefit from immediate practical impacts. Apprentices have improved information assurance audits at Lincoln University, created artificial intelligence policies for Norfolk and Waveney Integrated Care Board, and developed triage request processes for data protection requirements at The Christie NHS Foundation Trust.

Stacey Lawrence, Data Protection Manager at Manchester Airport, emphasises this value: 

“The impact that both apprentices have brought to Manchester Airport has been huge. They work on the front line, to manage all enquiries, data protection breaches, and individual rights requests, and without them we simply wouldn’t be able to do the really sterling work that we do every day.”

A Future-Focused Approach

Damar continues to evolve the programme based on feedback from coaches, apprentices, and employers. Recent improvements include enhanced EPA preparation sessions, now embedded into group coaching. The company maintains close ties with the trailblazer group and leverages Act Now’s expertise to stay ahead of legislative developments.

With another 22 apprentices due to commence in April, the programme’s growth trajectory remains strong. Many employers, including Manchester Airport Group and Nottingham University Hospitals, are returning for their second or third data protection apprentice – perhaps the strongest testament to the programme’s value.

For organisations seeking to strengthen their data protection capabilities and individuals looking to build rewarding careers in this critical field, Damar Training’s Data Protection and Information Governance Apprenticeship offers a proven pathway to success.

If you would like to learn more about the DP and IG  Apprenticeship, please get in touch