None

Financial penalty

Reprimand, no fine

10 March 2023

Date on the register

UK GDPR

Law relied on

UK GDPR Article 32(1), UK GDPR Article 32(1)(b)

Online technology and telecoms

Sector

7 actions on the register

In one line

The ICO issued Gain Capital UK Limited with a reprimand on 10 March 2023 under the UK General Data Protection Regulation. No financial penalty attaches to it.

01The record

Organisation named: Gain Capital UK Limited
Action: Reprimand
Date published: 10 March 2023
Register year: 2023
Law relied on: UK GDPR
Provisions cited: UK GDPR Article 32(1), UK GDPR Article 32(1)(b), UK GDPR Article 32(2), UK GDPR Article 58(2)(b)
Penalty: None (not a financial penalty)
Sector on the register: Online technology and telecoms
ICO register reference: 17265
Register status: Published on the ICO enforcement register, 4 September 2026
Notice documents: 1 PDF published by the ICO
Sector share of register: 7 of 216 actions (3%)
Actions published that year: 80
Actions under this law: 95
Position on the register: 40th of 216, oldest first
Published the same day: This entry alone

02What happened, and where it sits

Gain Capital UK Limited received an ICO reprimand on 10 March 2023. The Commissioner acted under the UK General Data Protection Regulation, citing UK GDPR Article 32(1), UK GDPR Article 32(1)(b), UK GDPR Article 32(2) and UK GDPR Article 58(2)(b). A formal criticism on the public record. A reprimand carries no fine and no order, but it is published and the ICO expects the shortcomings named in it to be fixed.

No sum is attached to this action. Reprimands are corrective, not financial, which is why Gain Capital UK Limited appears on the register without a figure beside it.

Gain Capital UK Limited is filed under Online technology and telecoms, which accounts for 7 of the 216 actions on the register (3%). In 2023 the ICO published 80 enforcement actions in total, 37 of them reprimands. 95 actions on the register name UK GDPR.

Counted from the oldest entry forward, this is the 40th of 216 actions on the register and the 1st of 7 in Online technology and telecoms. The ICO publishes one document for this action, 172 KB in total: "Gain Capital Reprimand 20230310". It is the authority for everything on this page.

03The ICO's own account

Gain Capital UK have been issued a Reprimand in respect of Articles 32 (2) and 32 (1) (b). An unauthorised third party leveraged an unpatched software vulnerability to access Gain Capital’s systems and exfiltrate personal data relating to 72,361 UK Data Subjects. Gain Capital had a support contract in place with a third party whom they believed were responsible for notifying Gain Capital about software security updates, however the contract stipulated that upgrades were Gain Capital’s responsibility.

Quoted from the ICO's published register entry (ico.org.uk), Open Government Licence v3.0.

The law behind this action

UK GDPR

The UK GDPR is the data protection regime the ICO enforces against controllers and processors. Its upper tier is capped at £17.5 million or 4% of total worldwide annual turnover, whichever is higher.

All 95 register actions under UK GDPR

What a reprimand does

A formal criticism on the public record. A reprimand carries no fine and no order, but it is published and the ICO expects the shortcomings named in it to be fixed.

Published notice

PDFGain Capital Reprimand 20230310(172 KB)

04Nearest entries on the register

Closest by sector, law and date
Organisation	Date	Action	Law	Penalty	Sector
TikTok Information Technologies UK Limited and TikTok Inc (TikTok)	15 May 2023	Monetary penalty	UK GDPR	£12,700,000	Online technology and telecoms
LastPass UK Ltd	20 Nov 2025	Monetary penalty	UK GDPR	£1,228,283	Online technology and telecoms
MediaLab.AI, Inc.	4 Feb 2026	Monetary penalty	UK GDPR	£247,590	Online technology and telecoms
Reddit, Inc.	23 Feb 2026	Monetary penalty	UK GDPR	£14,472,500	Online technology and telecoms
NHS Highland	9 Mar 2023	Reprimand	UK GDPR	-	Health

All Online technology and telecoms actions/All 2023 actions/The full register

05Work out an exposure of your own

Article 83 fine calculator

Estimate upper and lower tier exposure from turnover and infringement type, on the same scale the ICO works to.

How a fine is calculated

The Article 83(2) factors, the turnover caps, and how a regulator gets from a contravention to a number.

The ICO profile

How the UK regulator works post-Brexit, the £17.5M and £8.7M UK GDPR caps, and its divergence from the EU regime.

Provenance and independence

Source: ICO enforcement register (ico.org.uk/action-weve-taken/enforcement/), as published on 4 September 2026. Contains public sector information licensed under the Open Government Licence v3.0.

GDPRFine.com is an independent tracker of ICO enforcement. It is not affiliated with, endorsed by or connected to the Information Commissioner's Office, and it uses no ICO branding. Where the ICO's own wording is reproduced it is quoted and attributed; everything else on these pages is our own summary of the published record.

The ICO's register held 222 entries on that date. 6 of them are prosecutions of named individuals, with ages and home towns in the ICO's own summary. This tracker indexes organisations, so those 6 are excluded and every count on these pages is out of 216. They remain on the ICO's own register.

An entry says what the Commissioner did on the date shown. It is not a statement about the organisation today, and the ICO can amend or remove a register entry at any time. Amounts and provisions are as published by the ICO; where the published notice does not state a figure or name a provision, these pages say so rather than filling the gap. This entry was read from the register page at https://ico.org.uk/action-weve-taken/enforcement/2023/03/gain-capital-uk-limited/.