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Setting a New Standard: UK’s First ICO-Approved UK GDPR Code of Conduct
When the Association of British Investigators (ABI) wanted to help members improve accountability and build trust with clients, it turned to Stephenson Harwood for support. We worked together on developing the UK’s first-ever UK GDPR Code of Conduct for Investigative & Litigation Support Services - a landmark achievement that sets a new standard for professionalism and ethics in the industry.
In October 2024, the Information Commissioner’s Office (ICO) officially approved the Code, making it the first of its kind in the UK. This milestone demonstrates the sector’s commitment to compliance with complex data protection laws and offers practical guidance for investigators navigating the challenges of handling personal data.
“The Code gives private investigators clear rules to follow so they stay in line with GDPR,” said Tony Imossi, ABI’s head of secretariat and a renowned international investigator. “Our aim was to establish a trust mark in data. Professional investigation is a sector that attracts scrutiny for how it handles personal data in providing its services. The Code guides investigators and agencies on how to carry out detailed investigations while protecting people’s privacy and making sure data is used properly and legally.”
The impact of the Code has been recognised beyond the investigative sector, with Tony Imossi shortlisted for the prestigious ‘Privacy Champion of the Year 2025’ category at the PICCASO Awards.
Katie Hewson, a partner and data privacy expert at Stephenson Harwood said: “It has been a great privilege to work with the Association of British Investigators on this very important project, which will play a significant role in setting a new standard for professionalism, ethics, and accountability in the professional investigators sector, as well as positioning the ABI as a model for self-regulation.”
Founded in 1913, the ABI is the leading organisation in the UK’s largely unregulated investigative industry. It boasts the largest directory of accredited professional investigators in the UK, with members around the world who meet the ABI’s stringent membership criteria. The organisation takes a proactive role in promoting self-regulation and accountability among legitimate professional investigators.