UK GDPR (the post-Brexit version of EU GDPR) has been law since January 2021. The ICO's enforcement appetite increased significantly in 2024-25 — multiple seven-figure fines and increased focus on technical + organisational measures (TOMs). This is the practical IT-team guide to the three GDPR workflows that hit IT hardest: DPIAs, DSARs, and data residency.
DPIA — Data Protection Impact Assessment
Required for any new processing likely to result in high risk to data subjects. Deployment of new CRM, new analytics platform, new monitoring tool, new identity system — DPIA before go-live.
IT teams don't own the DPIA (DPO does) but provide the technical detail — data flow diagrams, retention period, encryption at rest + in transit, access control model, third-party data sharing.
A well-prepared DPIA template + IT pre-fill saves 70%+ of the DPO's drafting time. Build the template once, reuse for every new processing initiative.
DSAR — Data Subject Access Request
30-day response window (extendable by 60 days for complex requests).
IT teams build the search + extraction capability. Microsoft Purview Communication Compliance + eDiscovery, Google Workspace Vault, Salesforce DSAR tools, custom database queries.
Risk: missed DSAR = ICO complaint = enforcement attention. Operational discipline matters.
Volume reality: most mid-market UK orgs receive 5-50 DSARs per year. Some receive 500+ (consumer brands, multi-site retailers).
Data residency + international transfers
Post-Brexit: UK is a "third country" from EU perspective. Adequacy decision (granted June 2021, renewed 2025) keeps EU→UK transfers possible.
UK→US transfers — UK-US Data Bridge (extension of EU-US Data Privacy Framework) applies since October 2023. Specific to vendors signed up to the framework.
Major cloud + SaaS vendors all support UK data residency options. Microsoft 365 UK datacentre, AWS UK regions, Azure UK regions, Salesforce UK + EU regions, etc.
IT teams should document data residency per system in the Record of Processing Activities (RoPA).
Technical + organisational measures (TOMs)
Article 32 requires TOMs proportionate to risk. ICO enforcement increasingly tests specific TOMs.
Standard expected TOMs: encryption at rest, encryption in transit, MFA on access to personal data systems, audit logging, regular penetration testing, incident response plan, staff training, joiner/mover/leaver process — all visible in identity + access management.
Most ICO enforcement fines in 2024-25 cited missing or weak TOMs as primary aggravating factor. Pair UK GDPR work with Cyber Essentials Plus + ISO 27001 Annex A to evidence the technical baseline.
What Servnet does
Servnet supports UK GDPR technical controls — encryption deployment, identity governance, audit logging, DPIA template development, DSAR tooling integration. We don't replace your DPO but we provide the IT-side enablement — and tie evidence into our compliance + governance practice.