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Hang on. Does that mean any time we've contacted the ICO for advice recently, that advice has been based on DPA not GDPR, and may therefore be inaccurate in 91 days, 12 hours and 58 minutes? (www.GDPRcountdownclock.com !)

 

In principle, yes. You would be advised on the basis of current legislation. However, one would have thought that, were things to be radically different then the advice would include the phrase "However, under GDPR ..."

I think the important thing to note, though, is that there is no reason to believe that the ICO will not continue to take a reasoned and pragmatic approach to the issue of archived data when GDPR becomes law.

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