None

Financial penalty

Reprimand, no fine

9 March 2023

Date on the register

UK GDPR

Law relied on

UK GDPR Article 5(1)(f)

Health

Sector

15 actions on the register

In one line

The ICO issued NHS Highland with a reprimand on 9 March 2023 under the UK General Data Protection Regulation. No financial penalty attaches to it.

01The record

Organisation named: NHS Highland
Action: Reprimand
Date published: 9 March 2023
Register year: 2023
Law relied on: UK GDPR
Provisions cited: UK GDPR Article 5(1)(f)
Penalty: None (not a financial penalty)
Sector on the register: Health
ICO register reference: 17263
Register status: Published on the ICO enforcement register, 4 September 2026
Notice documents: 1 PDF published by the ICO
Sector share of register: 15 of 216 actions (7%)
Actions published that year: 80
Actions under this law: 95
Position on the register: 39th of 216, oldest first
Published the same day: This entry alone

02What happened, and where it sits

NHS Highland received an ICO reprimand on 9 March 2023. The Commissioner acted under the UK General Data Protection Regulation, citing UK GDPR Article 5(1)(f). 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 NHS Highland appears on the register without a figure beside it.

NHS Highland is filed under Health, which accounts for 15 of the 216 actions on the register (7%). 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 39th of 216 actions on the register and the 6th of 15 in Health. The ICO publishes one document for this action, 185 KB in total: "NHS Highland Reprimand". It is the authority for everything on this page.

03The ICO's own account

A formal reprimand has been issued to NHS Highland, which emailed 37 people likely to be accessing HIV services, inadvertently using CC (carbon copy) instead of BCC (blind carbon copy). The error meant recipients of the email could see the personal email addresses of other people receiving the email, with one person confirming they recognised four other individuals, one of whom was a previous sexual partner.

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.

Published notice

PDFNHS Highland Reprimand(185 KB)

04Nearest entries on the register

Closest by sector, law and date
Organisation	Date	Action	Law	Penalty	Sector
University Hospitals Bristol and Weston NHS Foundation Trust	7 Mar 2023	Reprimand	UK GDPR	-	Health
NHS Blood and Transplant	3 Mar 2023	Reprimand	UK GDPR	-	Health
University Hospitals Dorset NHS Foundation Trust	25 Apr 2023	Reprimand	UK GDPR	-	Health
The Patient and Client Council	19 Jul 2023	Reprimand	UK GDPR	-	Health
NHS Lanarkshire	31 Jul 2023	Reprimand	UK GDPR	-	Health

All Health actions/All 2023 actions/The full register

05Work out an exposure of your own

Article 83 fine calculator

Estimate upper and lower tier exposure from turnover and infringement type, on the same scale the ICO works to.

How a fine is calculated

The Article 83(2) factors, the turnover caps, and how a regulator gets from a contravention to a number.

The ICO profile

How the UK regulator works post-Brexit, the £17.5M and £8.7M UK GDPR caps, and its divergence from the EU regime.

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/2023/03/nhs-highland/.