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When Data Misuse Becomes a Proceeds of Crime Issue – The UK ICO’s Growing Use of Confiscation Orders

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The ICO has stepped up its enforcement by securing confiscation orders totalling almost £475,000 against individuals who profited...

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The ICO has stepped up its enforcement by securing confiscation orders totalling almost £475,000 against individuals who profited from the unlawful sale of personal data, signalling a tougher approach to data misuse for financial gain.While the action was aimed at employees rather than their employers, the cases raise important questions for organizations about governance, oversight, and responding to data incidents.Read the <a href="https://datadecoded.mofo.com/topics/when-data-misuse-becomes-a-proceeds-of-crime-issue-the-uk-ico-s-growing-use-of-confiscation-orders" target="_blank">full blog post</a>.

When Data Misuse Becomes a Proceeds of Crime Issue – The UK ICO’s Growing Use of Confiscation Orders

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As a member of our renowned global data privacy team, Annabel Gillham specializes in employee data protection and data crisis management. Described by clients as “excellent, very pragmatic, efficient and completely client-oriented”, she works across a variety of sectors, including technology, retail, and financial services, and frequently manages multi-jurisdictional advice for international clients. Her practice includes advice on:<ul><li>cross-border labor and employment matters</li><li>employee litigation</li><li>data privacy compliance management</li><li>data security breach management</li><li>internal and regulatory investigations</li></ul>Annabel regularly helps senior management and HR executives with the “people” aspects of takeovers, restructuring projects, business and share sales, and outsourcings. She also advises employers in relation to sensitive claims, such as unlawful discrimination, equal pay, and whistleblowing. Annabel also advises on team moves.She supports her clients on all aspects of General Data Protection Regulation compliance and regularly advises organizations facing ICO enforcement action. She has developed particular specialties in complex areas, such as the collection and use of data relating to criminal offenses and the application of data protection law to insolvency practitioners.As an experienced litigator with experience in helping clients defend group litigation, Annabel helps clients develop their strategy for responding to regulatory action and court claims relating to the use of employee and customer personal data. She regularly designs and presents employment and data protection law training and updates to senior managers and HR executives and is involved in preparing responses to UK government consultations.In addition, Annabel is qualified to practice in the British Virgin Islands, where she spent three years advising on cross border commercial litigation and insolvency matters, including high value board and shareholder disputes, freezing orders, and third-party disclosure orders.

Annabel Gillham

Partner

Hayley specializes in representing financial institutions, corporate clients and senior individuals in highly sensitive litigation, regulatory enforcement matters and internal investigations. She is Head of Morrison Foerster’s European Compliance Practice and regularly advises clients in relation to their compliance program and diligence of third parties.Hayley has advised clients facing parallel enforcement actions in multiple jurisdictions and those facing parallel criminal, regulatory and civil litigation. Hayley has advised clients on diverse matters across Europe, the Americas, Asia, the Middle East and Africa in the banking/financial services, energy, chemicals, construction/engineering, manufacturing and technology industries. She is also a member of our global Sustainability + Corporate Responsibility steering committee.In addition, Hayley has an active sanctions practice and frequently guides clients through complex UK financial sanctions and export control issues, including making license applications and interfacing with the Office of Sanctions Implementation (OFSI) and the Foreign, Commonwealth & Development office (FCDO).Hayley has been recognized as a Next Generation Partner and described in the Legal 500 UK as “…massively experienced with an enormous breadth of knowledge when dealing with the most complex cross-border regulatory investigations. She combines an excellent intellect with really practical application. Top quality.” “She’s a very able lawyer whose commercial practice covers a wide range of areas, and she’s adept at each of them; she’s clever, tough, charming and a delight to work with. Clients love her, as does her legal team: she provides encouragement, reassurance and adept handling of the most difficult case. First-rate.”Hayley is also recognized in Chambers UK, with clients commenting on her ability to “combine strong communication skills with excellent legal expertise. She is a strong collaborative partner to work with… she is ridiculously hard-working and has great judgement on how to cut through everything. She is a great person to have on your side.” Hayley was named by Global Investigations Review (GIR) to its list of Women in Investigations in 2021.Hayley was formerly an Investigative Lawyer at the Serious Fraud Office in the UK.

Hayley Ichilcik

Brittnie Moss-Jeremiah is an associate in the firm’s London office and a member of Morrison Foerster’s global Data, Cyber + Privacy Group.Brittnie advises clients on a broad spectrum of data protection, privacy and security issues, covering contentious, advisory and regulatory matters and transaction-related data challenges. She also has experience guiding clients through the evolving data privacy regulations across the UK, Europe and globally. With strong interests in digital media, artificial intelligence and technology, Brittnie’s experience extends to assisting clients in these sectors to navigate the privacy frameworks that impact their operations.Brittnie actively contributes to the firm’s pro bono initiatives and is committed to making a positive social impact by supporting a diverse range of clients, including domestic and international charities, as well as social impact businesses, with their privacy compliance obligations. She is particularly passionate about supporting pro bono initiatives that benefit marginalised communities.Brittnie trained at Morrison Foerster, gaining experience in the Litigation, Technology Transactions, Data Privacy, Corporate M&A, Capital Markets and Tax teams.Brittnie studied Law with Spanish and Spanish Law at the University of Nottingham. She subsequently earned distinctions in her LL.M. in International Business Law, with a specialist interest in Artificial Intelligence and Cyberlaws, and her Legal Practice Course at the University of Law.Brittnie is qualified as a solicitor in England and Wales and is professionally proficient in Spanish.