EU Regulation 2016/679 - Decision Register

ICO / 2023 / 17260/REPRIMAND

Chartered Institute for Securities & Investment

ReprimandUK GDPR21 February 2023

None

Financial penalty

Reprimand, no fine

21 February 2023

Date on the register

UK GDPR

Law relied on

UK GDPR Article 58(2)(b)

Charitable and voluntary

Sector

4 actions on the register

In one line

The ICO issued Chartered Institute for Securities & Investment with a reprimand on 21 February 2023 under the UK General Data Protection Regulation. No financial penalty attaches to it.

01The record

Organisation named
Chartered Institute for Securities & Investment
Action
Reprimand
Date published
21 February 2023
Register year
2023
Law relied on
UK GDPR
Provisions cited
UK GDPR Article 58(2)(b)
Penalty
None (not a financial penalty)
Sector on the register
Charitable and voluntary
ICO register reference
17260
Register status
Published on the ICO enforcement register, 4 September 2026
Notice documents
1 PDF published by the ICO
Sector share of register
4 of 216 actions (2%)
Actions published that year
80
Actions under this law
95
Position on the register
35th of 216, oldest first
Published the same day
This entry alone
People affected
654

02What happened, and where it sits

Chartered Institute for Securities & Investment received an ICO reprimand on 21 February 2023. The Commissioner acted under the UK General Data Protection Regulation, citing UK GDPR Article 58(2)(b). A formal criticism on the public record. A reprimand carries no fine and no order, but it is published and the ICO expects the shortcomings named in it to be fixed.

No sum is attached to this action. Reprimands are corrective, not financial, which is why Chartered Institute for Securities & Investment appears on the register without a figure beside it.

The notice puts numbers on the contravention: 654 people affected. Those figures are the ICO's, taken from the published notice for this action.

Chartered Institute for Securities & Investment is filed under Charitable and voluntary, which accounts for 4 of the 216 actions on the register (2%). In 2023 the ICO published 80 enforcement actions in total, 37 of them reprimands. 95 actions on the register name UK GDPR.

Counted from the oldest entry forward, this is the 35th of 216 actions on the register and the 1st of 4 in Charitable and voluntary. The ICO publishes one document for this action, 205 KB in total: "Chartered Institiute for Securities and Investment Reprimand". It is the authority for everything on this page.

03The ICO's own account

An unauthorised third party exploited a known vulnerability in the Sitefinity software to leverage a bruteforce attack to upload a malicious code to the Chartered Institute for Securities & Investment (CISI)’s website checkout page. The code captured payment details of an estimated 3,883 UK Data Subjects, as well as other personal data including names and email addresses.

CISI instructed a third party to conduct a forensic investigation which found that CISI were running unsupported software which had a number of vulnerabilities, one of which was a critical vulnerability for which a security patch had been available since 2017. CISI also advised that no penetration tests had been conducted prior to the incident, and that 654 Data Subjects had reported fraudulent activities on the payment cards affected by the incident.

CISI may have missed opportunities to identify the data breach earlier, as a number of individuals had reported card fraud prior to a group notification 14 April 2020, at which point CISI conducted a full investigation.

Quoted from the ICO's published register entry (ico.org.uk), Open Government Licence v3.0.

The law behind this action

UK GDPR

The UK GDPR is the data protection regime the ICO enforces against controllers and processors. Its upper tier is capped at £17.5 million or 4% of total worldwide annual turnover, whichever is higher.

All 95 register actions under UK GDPR

What a reprimand does

A formal criticism on the public record. A reprimand carries no fine and no order, but it is published and the ICO expects the shortcomings named in it to be fixed.

04Nearest entries on the register

All Charitable and voluntary actions/All 2023 actions/The full register

05Work out an exposure of your own

Provenance and independence

Source: ICO enforcement register (ico.org.uk/action-weve-taken/enforcement/), as published on 4 September 2026. Contains public sector information licensed under the Open Government Licence v3.0.

GDPRFine.com is an independent tracker of ICO enforcement. It is not affiliated with, endorsed by or connected to the Information Commissioner's Office, and it uses no ICO branding. Where the ICO's own wording is reproduced it is quoted and attributed; everything else on these pages is our own summary of the published record.

The ICO's register held 222 entries on that date. 6 of them are prosecutions of named individuals, with ages and home towns in the ICO's own summary. This tracker indexes organisations, so those 6 are excluded and every count on these pages is out of 216. They remain on the ICO's own register.

An entry says what the Commissioner did on the date shown. It is not a statement about the organisation today, and the ICO can amend or remove a register entry at any time. Amounts and provisions are as published by the ICO; where the published notice does not state a figure or name a provision, these pages say so rather than filling the gap. This entry was read from the register page at https://ico.org.uk/action-weve-taken/enforcement/2023/02/chartered-institute-for-securities-investment/.

Register: ico.org.uk/action-weve-taken/enforcement/. Corrections: [email protected].

REGISTER UPDATED 2026-04-28