The Information Commissioner’s Office (ICO) has published a consultation on plans to update its approach to handling complaints that it receives, proposing that a new framework is introduced which will allow it to triage each complaint and determine the appropriate level of investigation.  

As the consultation explains, the ICO’s current approach to complaints does not involve any mechanism for prioritising certain cases. Some cases which involve a high risk of serious harm or attract significant media attention may be flagged on an ad hoc basis, but otherwise cases are assigned in chronological order. Added to this, the ICO states that its current model is increasingly stretched by the volume of complaints it receives (estimated to be in the region of 50,000 this year), leading to a growing backlog and meaning that it is “taking longer to address people’s concerns and…it [is] more difficult to consistently deliver impactful outcomes”. 

To address this, the ICO proposes the introduction of a new framework which will be used to determine the extent to which it is appropriate to investigate each complaint. Cases will be examined by reference to a set of criteria which include those factors which may increase the need to investigate further such as whether the matter is likely to cause a high level of harm or affect a substantial number of people. Those factors which may reduce the need to investigate further include matters such as whether the ICO is already aware of the issue or if the organisation that is the subject of the complaint is already taking steps to respond to it.  

Having assessed the complaint against the criteria within the framework, a case officer may decide either to record the case for information only, to write to the organisation with guidance, or to allocate it to a team for further investigation. 

The new process will also allow the ICO to monitor complaint volumes across specific organisations and sectors, meaning that it can identify when a defined number of complaints is received about an organisation within a specific period, or when the number of complaints increase by a defined percentage amount. Again, if an organisation is flagged, the ICO may carry out an initial analysis to determine the appropriate next steps. 

The consultation closes on 31 October 2025 can be read in full here.