EU Regulation 2016/679 - Decision Register

ICO / 2023 / 17269/REPRIMAND

Surrey Police

ReprimandUK GDPR3 April 2023

None

Financial penalty

Reprimand, no fine

3 April 2023

Date on the register

UK GDPR

Law relied on

DPA 2018 section 35, DPA 2018 section 45

Criminal justice

Sector

26 actions on the register

In one line

The ICO issued Surrey Police with a reprimand on 3 April 2023 under the UK General Data Protection Regulation. No financial penalty attaches to it.

01The record

Organisation named
Surrey Police
Action
Reprimand
Date published
3 April 2023
Register year
2023
Law relied on
UK GDPR
Provisions cited
DPA 2018 section 35, DPA 2018 section 45
Penalty
None (not a financial penalty)
Sector on the register
Criminal justice
ICO register reference
17269
Register status
Published on the ICO enforcement register, 4 September 2026
Notice documents
1 PDF published by the ICO
Sector share of register
26 of 216 actions (12%)
Actions published that year
80
Actions under this law
95
Position on the register
44th of 216, oldest first
Published the same day
3 actions dated 3 April 2023

02What happened, and where it sits

Surrey Police received an ICO reprimand on 3 April 2023. The Commissioner acted under the UK General Data Protection Regulation, citing DPA 2018 section 35 and DPA 2018 section 45. 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 Surrey Police appears on the register without a figure beside it.

Surrey Police is filed under Criminal justice, which accounts for 26 of the 216 actions on the register (12%). 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 44th of 216 actions on the register and the 6th of 26 in Criminal justice. The ICO published 3 actions on 3 April 2023, so this one was part of a batch: Achieving for Children (reprimand) and Sussex Police (reprimand). The ICO publishes one document for this action, 401 KB in total: "Surrey-Police". It is the authority for everything on this page.

03The ICO's own account

In June 2020, the ICO became aware that staff members across both Sussex Police and Surrey Police had access to an app that recorded all incoming and outgoing phone calls. 1,015 staff members downloaded the app onto their work mobile phones and more than 200,000 recordings of phone conversations, likely with victims, witnesses, and perpetrators of suspected crimes, were automatically saved.

The ICO considered it highly likely that the app captured a large variety of personal data during these calls and it considered that the processing of some of this data was unfair and unlawful. Police officers that downloaded the app were unaware that all calls would be recorded, and people were not informed that their conversations with officers were being recorded.

The app has now been withdrawn from use and the recordings, other than those considered to be evidential material, have been destroyed.

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

04Published the same day

2 other actions carry the date 3 April 2023
OrganisationDateActionLawPenaltySector
Achieving for Children3 Apr 2023ReprimandUK GDPR-Social care
Sussex Police3 Apr 2023ReprimandUK GDPR-Criminal justice

05Nearest entries on the register

All Criminal justice actions/All 2023 actions/The full register

06Work 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/2023/04/surrey-police/.

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

REGISTER UPDATED 2026-04-28