@neil @badambassador @hedders In my experience ICO action relies on strongly felt opinions from data subjects raising complaints - usually resulting in a "bad dog, don't do it again" from ICO (giving the offender enough intel to tighten up their data opsec).
Most of the breaching organisations (for both PECR and DPA) feel it is their right to make money, and try a smokescreen of "you can't prove it was us spamming you / selling your data".
There's nothing proactive in this space.
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