None

Financial penalty

Reprimand, no fine

19 October 2023

Date on the register

UK GDPR

Law relied on

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

General business

Sector

20 actions on the register

In one line

The ICO issued Gap Personnel Holdings Limited with a reprimand on 19 October 2023 under the UK General Data Protection Regulation. No financial penalty attaches to it.

01The record

Organisation named: Gap Personnel Holdings Limited
Action: Reprimand
Date published: 19 October 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(1)(d)
Penalty: None (not a financial penalty)
Sector on the register: General business
ICO register reference: 17312
Register status: Published on the ICO enforcement register, 4 September 2026
Notice documents: 1 PDF published by the ICO
Sector share of register: 20 of 216 actions (9%)
Actions published that year: 80
Actions under this law: 95
Position on the register: 94th of 216, oldest first
Published the same day: This entry alone

02What happened, and where it sits

Gap Personnel Holdings Limited received an ICO reprimand on 19 October 2023. The Commissioner acted under the UK General Data Protection Regulation, citing UK GDPR Article 32(1), UK GDPR Article 32(1)(b) and UK GDPR Article 32(1)(d). 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 Gap Personnel Holdings Limited appears on the register without a figure beside it.

Gap Personnel Holdings Limited is filed under General business, which accounts for 20 of the 216 actions on the register (9%). 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 94th of 216 actions on the register and the 4th of 20 in General business. The ICO publishes one document for this action, 257 KB in total: "Gap Personnel Holdings Limited reprimand". It is the authority for everything on this page.

03The ICO's own account

The Information Commissioner (the Commissioner) issues a reprimand to Gap Personnel Holdings Limited in respect of infringements of Article 32 (1), Article 32 (1) (b) and Article 32 (1) (d) of the UK GDPR. The organisation did not have appropriate security measures in place, which resulted in an unauthorised threat actor being able to access individuals personal data twice within a 12-month period.

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

PDFGap Personnel Holdings Limited reprimand(257 KB)

04Nearest entries on the register

Closest by sector, law and date
Organisation	Date	Action	Law	Penalty	Sector
GRS (Roadstone) Limited	14 Nov 2023	Reprimand	UK GDPR	-	General business
Recruitment company reprimand	9 Aug 2023	Reprimand	UK GDPR	-	General business
Direct Clothing Co. (UK) Limited	18 Jul 2022	Reprimand	UK GDPR	-	General business
23andMe	5 Jun 2025	Monetary penalty	UK GDPR	£2,310,000	General business
Police Service of Northern Ireland (PSNI)	26 Oct 2023	Reprimand	UK GDPR	-	Criminal justice

All General business 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/2023/10/gap-personnel-holdings-limited/.