None
Financial penalty
Enforcement notice, no fine
23 February 2024
Date on the register
UK GDPR
Law relied on
DPA 2018 section 149, DPA 2018 section 3
Transport and leisure
Sector
2 actions on the register
In one line
The ICO issued Serco Leisure Operating Limited and relevant associated Trusts with a enforcement notice on 23 February 2024 under the UK General Data Protection Regulation. No financial penalty attaches to it.
01The record
- Organisation named
- Serco Leisure Operating Limited and relevant associated Trusts
- Action
- Enforcement notice
- Date published
- 23 February 2024
- Register year
- 2024
- Law relied on
- UK GDPR
- Provisions cited
- DPA 2018 section 149, DPA 2018 section 3, UK GDPR Article 4(7), UK GDPR Article 5(1)(a), UK GDPR Article 6, UK GDPR Article 9
- Penalty
- None (not a financial penalty)
- Sector on the register
- Transport and leisure
- ICO register reference
- 17340
- Register status
- Published on the ICO enforcement register, 4 September 2026
- Notice documents
- 10 PDFs published by the ICO
- Sector share of register
- 2 of 216 actions (1%)
- Actions published that year
- 52
- Actions under this law
- 95
- Position on the register
- 125th of 216, oldest first
- Published the same day
- This entry alone
02What happened, and where it sits
Serco Leisure Operating Limited and relevant associated Trusts received an ICO enforcement notice on 23 February 2024. The Commissioner acted under the UK General Data Protection Regulation, citing DPA 2018 section 149, DPA 2018 section 3, UK GDPR Article 4(7) and UK GDPR Article 5(1)(a). An order to act. An enforcement notice requires the organisation to take, or stop taking, specified steps by a deadline, and failure to comply is itself an offence.
No sum is attached to this action. Enforcement notices are corrective, not financial, which is why Serco Leisure Operating Limited and relevant associated Trusts appears on the register without a figure beside it.
Serco Leisure Operating Limited and relevant associated Trusts is filed under Transport and leisure, which accounts for 2 of the 216 actions on the register (1%). In 2024 the ICO published 52 enforcement actions in total, 17 of them enforcement notices. 95 actions on the register name UK GDPR.
Counted from the oldest entry forward, this is the 125th of 216 actions on the register and the 2nd of 2 in Transport and leisure. The ICO publishes 10 documents for this action, 5.5 MB in total: "Serco Leisure Operating Limited enforcement notice", "Serco Jersey Limited enforcement notice", "Birmingham Community Leisure Trust Limited enforcement notice", "Bolton Community Leisure Limited enforcement notice", "Maidstone- Leisure Trust Limited enforcement notice", "More Leisure Community Trust Limited enforcement notice", "Northern Community Leisure Trust Limited enforcement notice", "Shropshire Community Leisure Trust Limited enforcement notice", "Swale Community Leisure enforcement notice" and "ICO orders Serco Leisure to stop using facial recognition technology". They are the authority for everything on this page.
03The ICO's own account
Serco Leisure, Serco Jersey and seven associated community leisure trusts have been issued enforcement notices ordering them to stop using facial recognition technology and fingerprint scanning to monitor employee attendance. The ICO's investigation found that Serco and the trusts have been unlawfully processing the biometric data of more than 2,000 employees at 38 leisure facilities for the purpose of monitoring attendance.
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.
What a enforcement notice does
An order to act. An enforcement notice requires the organisation to take, or stop taking, specified steps by a deadline, and failure to comply is itself an offence.
Published notice
- PDFSerco Leisure Operating Limited enforcement notice(642 KB)
- PDFSerco Jersey Limited enforcement notice(635 KB)
- PDFBirmingham Community Leisure Trust Limited enforcement notice(635 KB)
- PDFBolton Community Leisure Limited enforcement notice(635 KB)
- PDFMaidstone- Leisure Trust Limited enforcement notice(635 KB)
- PDFMore Leisure Community Trust Limited enforcement notice(635 KB)
- PDFNorthern Community Leisure Trust Limited enforcement notice(635 KB)
- PDFShropshire Community Leisure Trust Limited enforcement notice(635 KB)
- PDFSwale Community Leisure enforcement notice(598 KB)
- PDFICO orders Serco Leisure to stop using facial recognition technology
04Nearest entries on the register
| Organisation | Date | Action | Law | Penalty |
|---|---|---|---|---|
| Home Office | 21 Mar 2024 | Enforcement notice | UK GDPR | - |
| Bristol City Council | 27 Aug 2025 | Enforcement notice | UK GDPR | - |
| South Wales Police | 9 Oct 2025 | Enforcement notice | UK GDPR | - |
| Chief Constable West Midlands Police | 1 Mar 2024 | Reprimand | UK GDPR | - |
| The Central Young Men's Christian Association | 6 Mar 2024 | Reprimand | UK GDPR | - |
All Transport and leisure actions/All 2024 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/2024/02/serco-leisure-operating-limited-and-relevant-associated-trusts/.
Register: ico.org.uk/action-weve-taken/enforcement/. Corrections: [email protected].