Do you need to be ICO registered?

Information Commissioner's OfficeWe have been contacted a couple of times in the last week about the need for members to be registered with the ICO (Information Controllers Office) with particular with reference to the new GDPR rules coming into force later this month.

Seeking ICO guidance

My first thought was that although the Institute has to be registered there would continue to be no need for individual members to be registered.

I thought that I should attempt to verify this and so contacted the ICO for guidance. As so often happens with these Help lines the advice given is often very basic and will differ based on the information you provide about your business.

Nevertheless, in general, 2 points make it less likely that we need to register our businesses individually. First the data that we collect is actually ‘owned’ by the client and not ourselves.

Secondly, in most cases we do not keep any information that would be classed as personal data. For example, financial data such as that generated in a stock audit is not classed as personal data.

Self assess in just 30 seconds

However, it is advised that all members should carry out the assessment that can be found on their website. It literally takes thirty seconds – when you have found it!
Go to

Click on the yellow box on the right hand side of the screen (Register, Renew or Search the Register) and halfway down the subsequent page there is a link to ‘Take our quick self assessment to find out’.

It literally took me thirty seconds to complete.

Websites, mailshots, social media…

If you have a website with a contact form, you have a contact list for sending out mailshots or use social media for business then registration is more likely to be required. You will find more guidance on the ICO website.

Hope that helps, Chris.
Article written by Chris Swift FILSA

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