Policies and Assurance Checks: Up to Date or Out of Place?

Get Ahead!® with Your Policies and Assurance Checks

The recent reprimand of the Post Office by the Information Commissioner’s Office (ICO) is less about the technicalities of a single breach and more about what wasn’t in place to prevent it. For nearly two months in 2024, a sensitive legal document was left publicly accessible on the organisation’s corporate website. The real issue, however, was not simply the exposure of personal details — it was the absence of the basic safeguards that should have stopped such a mistake from happening at all.

What Went Wrong

The ICO found that the Post Office had:

• No documented publishing policies to guide staff on what could or could not be released.

• No quality assurance checks to catch errors before documents went live.

• Insufficient staff training (our focus this week is not about training — we will return to data protection training in the coming weeks).

  
  

In other words, the breach was “entirely preventable” because the organisation lacked the governance framework that makes compliance operational, not theoretical. You can read about the case by accessing the following link: Post Office reprimanded over Horizon IT scandal victims' ‘entirely preventable’ data breach | ICO.

Whilst the reprimand was widely published, the real lesson is clear — without policies and assurance, mistakes become breaches.

Why Policies and Assurance Matter

Publishing information online is not a trivial task. Every organisation needs clear rules about:

• Who is authorised to publish content.

• What checks must be carried out before publication.

• How sensitive information is identified and handled.

Without these policies, staff are left to make ad‑hoc decisions, and mistakes become inevitable. Quality assurance processes act as the safety net: they ensure that even if one person misses something, a second line of defence catches it before harm is done.

That's why we're sharing 10 Steps Towards Robust Policies and Assurance:-

Step 1–5: Getting Policies Right

1. Review existing policies — check what you already have and whether they are current.

2. Identify gaps — look for areas not covered, such as publishing practices or handling sensitive data.

3. Draft clear publishing rules — specify what can and cannot be released, and in what format.

4. Define responsibilities — set out who is authorised to approve and publish documents.

5. Record and communicate policies — ensure staff know where to find them and how to apply them.

   
   

Step 6–10: Building Assurance Processes

6. Establish a review process — require independent checks before documents go live.

7. Create sensitivity checklists — highlight personal data, confidential information, and reputational risks.

8. Maintain version control — ensure only the approved final version is uploaded.

9. Audit published content — schedule regular reviews to confirm compliance and accuracy.

10. Update policies and checks regularly — adapt to changes in law, technology, and organisational risk.

    
    

    These steps provide a foundation, but every organisation’s risks and workflows are different. Policies must be tailored, and assurance processes embedded into daily practice.

    
    

    The Bigger Picture

    The ICO’s findings underline how routine publishing errors can escalate into reputational crises when organisations lack basic governance. In this case, the absence of policies and checks caused the ICO to issue a reprimand for the data breach the regulator described as “entirely preventable.”

    
    

    Organisations across all sectors should take note: policies and assurance processes are not optional extras. They are the minimum safeguards expected under UK GDPR.

    
    

    Data Protection Management Consultants Get Ahead!® works with organisations to put those safeguards in place. If you want to avoid preventable breaches and strengthen trust with your stakeholders, now is the time to act — and we can help you get ahead.

Reach out today at support@dpmconsultants.co.uk or call us on +44 79497 119 764. We'll be happy to help!

This article was developed with support from AI-based editorial tools and reviewed for accuracy. Any similarity to existing content is purely coincidental and unintended.

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