“We’ve welcomed the constructive engagement from industry during the consultation process and now we are calling for action - data protection by design is a legal requirement, not a suggestion. We encourage organisations making and developing smart products to review the guidance and ensure they are meeting the standards the public expect.” 

We are now turning our attention to connected TVs and how they use people’s personal information. Found in 70% of UK households, smart TVs can collect a large amount of data and use this information to serve targeted advertising - but this must be done transparently and with genuine consent. 

We will be engaging with connected TV manufacturers this year to assess whether they are complying with the law and offering consumers meaningful choice over how their data is used. 

Andrew Laughlin, Which? Tech Expert, said:

"For years, Which? investigations have shown that many connected products collect far more personal data than is needed to provide their service, so it's good that the ICO has incorporated some of our recommendations into its final guidance, helping to set clearer expectations for manufacturers and developers.
 
"The guidance should mark a turning point for the sector. Businesses need to be upfront about the data they collect, explain why they need it and give consumers meaningful control over how it's used. The challenge now is ensuring the guidance is backed by effective regulation and meaningful industry action."

Our expectations for IoT manufacturers and developers 

• Privacy must be built in from the start, not bolted on afterwards - with protective settings on by default and data collection limited to what is strictly necessary.
• Consent must be real, specific and freely given via a clear opt-in - and it must be just as easy to withdraw.
• Genuine transparency is more than a privacy notice - users must be clearly informed about how their data is used, in plain language and at relevant points across the whole product.
• Most firms will have to do a Data Protection Impact Assessment – due to the sensitive nature of the data they collect, with an even higher bar if children may use the product.
• Security is an ongoing legal obligation, not a one-time consideration – it requires regular updates, encryption, and multifactor authentication throughout the product's lifetime.

The guidance forms part of our wider online tracking strategy, which aims to give people meaningful choice and confidence in how their information is used, while enabling businesses to innovate responsibly. 

Read the final guidance and consultation summary report on our website. 

The guidance covers the full range of consumer IoT products — including smart speakers, connected TVs, fitness trackers, smart doorbells, home hubs and domestic appliances — and applies to manufacturers, app developers, operating system providers, cloud providers, and others in the IoT supply chain. It does not cover smart meters, connected and autonomous vehicles, or IoT products used in enterprise and industrial settings. 

The Information Commissioner’s Office (ICO) is the UK’s independent regulator that exists to empower people through their information rights. The ICO regulates the whole economy, including government and the public sector.

The ICO has specific responsibilities set out in the Data Protection Act 2018 (DPA2018), the United Kingdom General Data Protection Regulation (UK GDPR), the Freedom of Information Act 2000, (FOIA), Environmental Information Regulations 2004 (EIR), Privacy and Electronic Communications Regulations 2003 (PECR) and a further five acts and regulations. 

The ICO can take action to address and change the behaviour of organisations and individuals that collect, use and keep personal information. This includes criminal prosecution, non-criminal enforcement and audit.  

To report a concern to the ICO telephone our helpline 0303 123 1113 or go to ico.org.uk/concerns.