Deputy Data Protection Commissioner Rachel Masterton looks back on 2025 and takes a punt on predicting what 2026 may bring.
In a year that featured a myriad of public engagement, enforcement actions and technological developments, for me, 2025 has two stand out areas I look back on fondly.
The first was hosting, in June, the 2025 meeting of the British Irish and Islands Data Protection Authorities (BIIDPA). This brought delegates from Bermuda, Gibraltar, Ireland, the Isle of Man, Jersey, Malta and the United Kingdom to our shores, providing an opportunity to share experiences, discuss common challenges and consider opportunities to cooperate, to the benefit of all our citizens and regulated communities.
The agenda for BIIDPA may have been unique amongst 2025 agendas, in that it did not specifically reference AI, the ‘big thing’ on the minds of businesses and regulators alike. Rather, reflecting the reality that AI is having an impact across the board and is no longer a distinct thing in its own right, it featured in pretty much every discussion, whether that be the risks it can pose, the innovation it can unlock or the benefits it can bring the regulators in attendance. My thanks go to all attendees for a great two days of discussion and learning, and to the ODPA team for helping make the event a success.
My second highlight was being let loose in the classroom to deliver our schools’ programme. With the ethos of talking with children and young people, rather than solely at them or about them, our Seeds programme presents the power of digital technology and how it is often not the tech itself that is either ‘good’ or ‘bad’. Rather it is down to how it is being used, something still very much in the hands of organisations, however much they may claim otherwise (see my article in October’s Business Brief for more information).
Such is the enthusiasm of our team to do our bit to keep children and young people safe while engaging with age-appropriate opportunities technology presents, I am one of five ODPA staff that your children may come home to tell you about. As well as sessions for Year 8 and Year 10 students, and to tie in with International Children’s Day on 20 November, we read our book, ‘Warro goes on an adventure’, to 27 Year 4 classes across 15 schools. Given the old adage not to work with children or animals, spare a thought for us wrangling hundreds of children and a very curious bear.
At the ODPA, we will begin 2026 with a renewed purpose and the launch, at the end of January, of our new Strategic Plan. Built around pillars of Balance, Trust and Partnership, this Strategic Plan is an evolution of existing practice, rather than a revolution, because, as Sir Terry Pratchett wrote, “Don’t put your trust in revolutions. They always come round again. That’s why they’re called revolutions.”
With a focus on outcomes (the impact of our actions and the differences they make) rather than outputs (things that can be counted), 2026 will see an increased emphasis on partnerships that benefit the Bailiwick and its citizens, as well as a continuation of our efforts to take a proportionate approach to enforcement action. We will continue to help those organisations that want to get it right and tackle significant poor practice and actions that cause harms with the tools available to us. More on that in the New Year.
And in closing, writing this in early November, it seems a little too early to consider season’s greetings, but by the December publication date, we will have started our advent calendars. So Merry Christmas to you all and watch this space for 2026’s data protection insights (and more slightly forced James Bond related titles).