UK Court of Appeal Rules on the Concept of Personal Data in the Context of Data Security

Sam Jungyun Choi, Jadzia Pierce, and Paul Maynard of Covington and Burling write: On February 19, 2026, the UK Court of Appeal handed down its decision in DSG Retail Limited v The Information Commissioner [2026] EWCA Civ 140. The Court ruled that a controller’s data security duty applies to all personal data for which it acts as…

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