2026 is shaping up to be the most consequential year for UK data protection enforcement since the introduction of the EU/UK GDPR regime. With record fines issued in late 2025, a new enforcement playbook on the horizon, and shifting legislative and regulatory expectations, the Information Commissioner’s Office (“ICO”) is signalling a marked transformation in how it supervises, and sanctions, organisations.
Too often, limitation of liability clauses are treated as standard boilerplate - something to tidy up at the end of a negotiation once the “real” commercial points are agreed.
In this article, we share 7 key considerations to help tech founders navigate the journey from seed funding to Series A and beyond.
In November 2025, the European Commission unveiled its Digital Omnibus package – a set of proposals aimed at simplifying (not deregulating) EU rules on data protection, cybersecurity and AI.
In a recent decision on the UK GDPR’s global scope, the Upper Tribunal in The Information Commissioner v Clearview AI Incorporated and Privacy International [2025] UKUT 319 (AAC) confirmed that the UK’s data protection regime can extend well beyond its borders.
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