What happened, who was affected, and what we can learn…
November was an unusual month as the ICO did not publish any new major enforcement actions or news releases about specific personal-data breaches affecting UK individuals. Instead, the regulator focused on policy, guidance and its “public sector approach”, which will shape how future breaches are handled and penalised.
The ICO’s News, blogs and speeches feed for November contains items like “Regulating for impact with our public sector approach” (11th November 2025) and a statement on the new Cyber Security and Resilience Bill (12th November 2025), but not a new named data-breach case.
The Enforcement action register, filtered around November 2025, similarly shows no fresh monetary penalties or reprimands published that clearly relate to a newly disclosed breach of personal data (as opposed to prior months’ cases being analysed in external commentary).
Given that, there are no new organisations to list this month under the detailed case fields (Date Reported, No. of UK Individuals Affected, etc.) without speculating beyond the public record.
So this month’s UK Data Breach Report is less about fresh incidents and more about how the rules of the game are changing.
Insights for UK Organisations
Even without new public breach cases, November still matters:
Public Sector Approach Clarified
The ICO published an updated explanation of its public sector approach, confirming that for most public authorities it prefers reprimands, enforcement notices and improvement work over large fines; reserving monetary penalties for the most serious and wilful failures.
Enforcement Procedure Under The Microscope
Law firms and risk advisers dissected the ICO’s draft enforcement procedural guidance, explaining how investigations will run and how factors like cooperation, remediation and financial hardship may influence outcomes.
Cyber Resilience Is Moving Up The Agenda
In a November statement, the ICO welcomed the introduction of the Cyber Security and Resilience (Network and Information Systems) Bill, flagging its importance for national cyber-resilience and data protection.
Children’s Data And Online Services Remain A Strategic Priority
The ICO’s November 2025 Children’s Code Interim Impact Review reiterated focus on platforms whose design choices can lead to data misuse or over-collection from children and young people.
Legislative Context
The Data (Use and Access) Act 2025 (DUAA) continues to roll out, with effects now visible in:
- Updated Guide to Law Enforcement Processing (4th November 2025), reflecting DUAA changes to logging and national-security exemptions.
- Ongoing consultations on enforcement procedural guidance, which will hard-wire new timeframes and processes into ICO investigations.
- External analyses (e.g. Osborne Clarke’s November 2025 regulatory outlook; BDO’s trends in ICO enforcement) highlight a trajectory towards more structured, predictable enforcement, especially around cyber incidents and poor breach handling.
In practice, this means that when the next big breach lands, the ICO will have a clearer, more formal playbook under DUAA and updated guidance.
Conclusion
November 2025 may look quiet on the surface—no new headline fines or named breaches—but behind the scenes, the ICO is doing the groundwork that will define how hard and how fast it hits organisations in future cases.
For controllers and processors, the message is simple:
- Use this “quiet” month to tighten your house—especially breach detection, logging and escalation.
- Watch the ICO’s guidance on the public sector approach and enforcement procedures; they’re not theory, they’re the rulebook that will be used when your incident lands on the ICO’s desk.
- Don’t mistake the absence of fresh publicity for a lack of regulatory activity; investigations often run for many months before appearing on the public register.
Disclaimer
This report is based on public disclosures, media reports, and ICO updates available at the time of writing. Figures for affected individuals may be estimated where not officially disclosed. This post is intended for informational purposes only and does not constitute legal advice.
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