**This blog was written by Nailah Ukaidi**
Following the ICO’s publication of their draft Corporate Strategy, SAVVI welcomes the ICO’s ambition to build trust in responsible UK data use and innovation and was pleased to respond the public consultation at the end of August 2026.
Protecting people’s information is essential. But so is using information responsibly, when it can identify risk earlier, prevent harm and connect people with support. The ICO’s strategy creates an exciting opportunity for public services to do both.
Prevention and early intervention are at the heart of SAVVI. SAVVI defines vulnerability as an increased risk of a poor outcome. Spot that risk earlier and public services have a better chance of acting before someone’s circumstances deteriorate. However, the information needed to see that risk is often spread across organisations. That is why responsible multi-agency data use and reuse matters.
SAVVI enables organisations to use, reuse and share the minimum information needed – lawfully, ethically and transparently – to identify increased risk and connect people with appropriate support.
Building Confidence to Use Data Responsibly:
Responsible use of data can itself help prevent harm. Public services need the confidence to act as too often, uncertainty about what is permitted can discourage legitimate preventative data use. Organisations need to understand where the boundaries are and what they cannot do. But they also need confidence in what they can do responsibly, particularly when using information responsibly could help identify risk earlier or prevent harm. That means greater clarity about what data protection law enables, not only what it restricts. General guidance is important, but public services need guidance they can actually use: guidance that helps them make good decisions and get things right the first time.
When a public service is designing a preventative approach, there are often practical questions to work through: what information can be used, what needs to be shared, how much is really needed, how should people be informed, and what safeguards are required? These questions arise across multi-agency data sharing, prevention, risk identification, data minimisation, profiling, governance, analytics and AI and they need those answers while services are being designed, not after something has gone wrong. This is where early engagement with the regulator could make a real difference. It can help organisations build privacy, transparency, proportionality and accountability into their approach from the start.
Across the country, public bodies are solving many of the same information-governance problems again and again. That is slow, expensive and unnecessary.
Don’t Solve the Same Problem Twice:
Across the public sector, organisations often find themselves addressing the same information governance, data sharing and service design challenges independently, even where similar approaches have already been developed and tested elsewhere. This can lead to duplicated effort, inconsistent practices and slower progress.
SAVVI’s common process, Information Governance Framework, data models, standards, templates and Playbook are designed so organisations do not have to keep starting from scratch. Public services should be able to build on approaches that have already been tested and developed, rather than starting from scratch each time. SAVVI’s common process, Information Governance Framework, data models, standards, templates and Playbook are designed to help organisations do just that.
We think the same principle could apply to regulatory learning. Where the ICO works with an organisation to solve a common information-governance problem, the learning could, wherever appropriate, be turned into a reusable pattern, framework, example or case study that others can build on. Solve it once. Help everyone move faster.
Standards Make this Scalable
Common standards can also make responsible data sharing easier to understand and apply across different organisations. Instead of every project creating its own approach, organisations can work from shared processes, terminology and expectations. That makes good practice easier to repeat and scale. The Government’s recommended Data Standards for sharing vulnerability data, supported by SAVVI, are helping organisations develop shared approaches to capturing, understanding, using and sharing the minimum information needed to support people at risk.
The aim is to make responsible data use more consistent and transparent, easier to audit and work with across organisational boundaries, and ultimately more reusable. We would like to see the ICO working alongside government, local government and standards bodies to help turn these principles into approaches that public services can understand, use and reuse in practice.
Setting out the ambition is only the first step. Public services now need practical guidance, confidence and support to put these principles into action. In our consultation response, SAVVI highlighted seven areas where we believe the ICO could make a real difference:
- Clarity about what responsible data use is permitted.
- Confidence for multi-agency data sharing for public benefit.
- Reusable guidance and patterns that solve common problems.
- Early regulatory engagement with innovation.
- Prevention and early intervention recognised as benefits of responsible data use.
- Common standards across organisational boundaries.
- Measuring success through better outcomes for people, not only through harm avoided.
For SAVVI, this is about moving the conversation beyond simply asking, “Can we share the data?”. A more useful question is, “How can we use data responsibly to identify risk earlier and improve outcomes?”. That is where SAVVI sees the real opportunity to influence the ICO’s strategy: moving from uncertainty to confidence, from one-off solutions to approaches that can be reused, and from reacting to problems to helping people earlier. This is definitely an opportunity worth getting excited about.
Find out more about SAVVI, explore our standards, frameworks and practical resources, and see how organisations are putting responsible data use into practice at Savviuk.org