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2026 marks a turning point for data governance in the UK
Caroline Sheldon
Caroline Sheldon joined the Corporate, Commercial & Finance team in August 2022 as an associate and specialises in advising on commercial matters. She advises entrepreneurs, startups and established businesses across a variety of sectors, with a focus on those in the technology sector.
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.
Founders and teams across the country are looking for signals that the UK still backs its innovators. Here’s what’s top of the wish-list:
For founders, investors and anyone involved in the tech sector, understanding who owns your software and how to prove it is critical. Whether you’re seeking investment, planning an exit or simply aiming to protect your IP, clarity on ownership can make or break a deal
The Court of Appeal has recently handed down an important decision in respect of data protection law considerations in Farley & Others v Paymaster (trading as Equiniti) [2025] EWCA Civ 1117, providing clarity on the scope of infringement and compensation data protection claims under the UK GDPR and Data Protection Act 2018 (“DPA”). The judgment will be of particular interest to any service provider dealing with and processing large volumes of customer personal data.
At some point in their history, businesses commonly have need for external funding to help their growth trajectory.
In tech, the law often arrives after something has gone wrong. Here are three cautionary tales* and the lessons every founder, CTO and in-house counsel should take away.
The Data (Use and Access) Act 2025 (the “DUAA”), which received Royal Assent on 19 June 2025, introduces targeted reforms to the UK data protection legal framework — particularly the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (“PECR”).
Many of you will know that the Government published, on 23 June, its Modern Industrial Strategy paper and, with it, committed to creating a “predictable, proportionate, and transparent investment screening framework” and launching a 12-week consultation on updating the definitions of the 17 sensitive sectors of the economy as set out in the National Security and Investment Act 2021 (NSIA).
The recent cyberattacks on major UK retailers have put cybersecurity back in the spotlight. But a more significant development for data protection practitioners has been flying under the radar: the Information Commissioner’s Office (ICO) has issued a notable fine directly against a data processor for breaching UK GDPR security obligations - an important shift in enforcement focus.
The 2023/24 tax year marks a major shift in the way unincorporated businesses are taxed. It is a transition year, with HMRC moving from the traditional “current year basis” to a “tax year basis” from 6 April 2024. While this change is intended to simplify the system in the long run, it introduces some short-term complexities (and often tax expense) during the transition year which partners and other sole traders ought to be alive to.
We have a wealth of experience acting for high net worth individuals at the outset of their angel investing journey and for seasoned angel investors who need the occasional bit of legal input.
On 6 April 2025, the first wave of consumer protection provisions under the Digital Markets, Competition and Consumers Act 2024 (“DMCC Act”) came into force, marking the most significant overhaul of UK consumer protection law in over a decade.
In the wake of recent high-profile cyber-attacks on major retailers like Marks & Spencer and Co-op, the UK government has launched a new voluntary Code of Practice for software vendors at its flagship cyber security event, CyberUK 2025. This initiative sets a dynamic baseline for software security and resilience, aiming to help prevent such breaches in the future.
The Office of Communications, commonly known as ‘Ofcom’ (the regulator for communication services) is calling on tech firms to make ‘the online world safer for women and girls’.
Criminal risk isn’t the first thing that comes to mind when considering the commercial drivers behind a merger or acquisition. But our recent roundtable discussion at our offices made clear that criminal liability—however peripheral it might seem—can have very real consequences for deal viability and post-completion exposure. Here are five key takeaways from a discussion that brought together legal and business perspectives on how economic crime intersects with transactional work.
In this blog, we dive into the essentials of share buybacks, explore common issues that arise when shareholders object, and uncover creative workarounds to navigate conflicts while staying compliant and maintaining trust.
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Caroline Sheldon
Christopher Perrin
Roberta Draper
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