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Blog: ICO regulatory sandbox

First reports published from the Regulatory Sandbox.

The first reports from participants in our regulatory sandbox have been published, revealing the outcomes of collaborations between the ICO and two of the organisations who were among the participants in the pilot phase of the scheme.

This beta phase set out to road test’ the scheme ahead of a full launch. We were seven months in when the pandemic struck, impacting businesses and organisations across the board in different ways.

As a result some of our participants were unable to continue working in the same way – so we worked flexibly with them to rescope their work with us. For some projects we have agreed extensions, and others have continued as planned and are now nearing the natural end of their projects

JISC and Heathrow Airport Ltd reports mark the first steps towards achieving the aim of the sandbox: to show that data protection can be combined with real world innovative solutions. 

When we launched the scheme in September 2019, we were extremely encouraged by the calibre and number of applications we received (63) from a broad range of sectors. The ten programmes that were selected, were chosen because they were viable and because of the real public benefit they could deliver through ground breaking products and services.

What was heartening for us was the fact that so many organisations wanted to work with us to prioritise data protection and incorporate it into their ideas from the outset. It was clear that both public and private sectors wanted to adopt a data protection by design approach – a cornerstone of the GDPR.

These are the first two reports, the other projects from the beta phase are at earlier stages in the scheme and their reports will be published on completion.

JISC – Wellbeing Code of Practice

JISC is a not-for-profit organisation serving the higher and further education and skills sectors. It champions the importance and potential of digital technologies for UK education and research.

Within the sandbox, JISC has developed a Wellbeing Code of Practice with universities and colleges who want to investigate the use of student activity data to improve their provision of student support services.

Helping them protect both their privacy and wellbeing.

It shows that good data protection can enable higher education providers to provide their duty of care to students by using the resources and data they already have available to them.

Heathrow Airport Ltd – Automation of the Passenger Journey programme

Heathrow Airport’s Automation of the Passenger Journey programme aimed to streamline the passenger journey by using biometrics. Facial recognition technology would be offered at check-in, self-service bag drops and boarding gates to create a seamless experience for passengers travelling through the airport. Passengers would no longer have to present different forms of documentation, such as boarding cards and passports, at different points in their journey to prove their identity and show that they are authorised to travel.


This first phase of the sandbox has been a beneficial experience for all parties, in our March blog we provided an update which reviewed progress made and the positive experiences of participants.

They have gained an insight into how data protection does not hinder innovation and how the two can work together. By working alongside us, they have also been able to help develop our views on compliance issues which have informed our own advice and guidance.

The ICO sandbox team has, in turn, expanded its understanding of how it can support organisations that are striving to innovate in a world where technology is moving at a fast pace and people are increasingly aware of their privacy rights.

This successful trial run, has given us the opportunity to introduce improvements ahead of the full launch. We will be publishing details about this, the new themes we will be focusing on and how organisations can register their interest in the near future.

In the meantime, we are always keen to hear from you and if you have any enquiries please contact

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