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Profiling: What the ICO Has To Say

The use of profiling can help businesses understand more about their target audiences, make better informed decisions about who to reach out to, and process data with better intelligence. Such information can give us insights into how a person behaves and what their personality is like, as well as what their interests and habits are – through consumer, social, or user profiling. With the evolution of profiling technology to help us achieve our marketing goals, it’s no wonder more and more businesses are using this technique to help widen their competitive gap.


However, if your profiling activity results in unfair discrimination, you may need to re-think your strategy now in preparation for GDPR. Lets’ take a look at the benefits and risks according to the ICO:



  • More effective market segmentation
  • Enables risk and fraud analysis
  • Aligns offers and prices with individual consumer demand
  • Contributes to improvements in medicine, education, healthcare and transportation
  • Provides access to credit via different methods vs traditional credit-scoring
  • Offers more consistency in decision making process



  • Creates infringement of fundamental rights and freedom
  • May underrepresent certain social sectors, eg elderly, vulnerable individuals, those with limited social media presence
  • Can deduce sensitive from non-sensitive personal data with reasonable certainty
  • Unjust deprivation of goods or services
  • Risk of creating a data broking industry to use data for their own interests without gaining individuals’ consent
  • Can jeopardise data accuracy


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And if you’re wondering what potential negative effects an individual can claim as a result of improper profiling, the ICO states:


  • Damage, loss or distress to individuals;
  • Limits to rights or denies an opportunity
  • Affects individuals’ health, well-being or peace of mind
  • Affects individuals’ financial or economic status or circumstances
  • Leaves individuals open to discrimination or unfair treatment
  • Involves the analysis of the special categories of personal or other intrusive data, particularly the personal data of children
  • Causes individuals to change their behaviour in a significant way
  • Unlikely, unanticipated or unwanted consequences for individuals


With this in mind, the ICO recommends considering establishing an externally recognised standard with which to measure these effects – rather than relying solely on the subjective view of the controller or data subject.


Stay Transparent


Profiling is not as transparent as other methods of data processing. Despite being considered a neutral process, the decision you make on an individual based on the information you collect, could have a significant impact on them beyond your control. Don’t forget also that because you create new data from a variety of sources, you need to ensure this is GDPR compliant. It’s worth therefore considering the following:


  •  How you will ensure your processing is effective, timely, and fair
  •  What individuals might reasonably expect from your profiling activity


In light of this, here are a few pointers to help you stay transparent and fair when it comes to profiling:

If your business is re-using personal data that is publicly available or obtained from a third party, make sure that the third party privacy notice adequately describes how the data will be further processed.

When re-using third party data, consider whether further processing is compatible with the original purpose.

Define and implement robust procedures to protect the quality and accuracy of the personal data you process. Make sure you have have ways of testing your systems to prove that your data is free-from-bias and accurate.


For the full report, head to the full ICO Feedback Request. If you need help defining what your legal basis is for profiling, or ensuring the profiling you carry out do is fair and free from unjustified impact, contact us today.


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