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The ICO announced a two-year trial of a revised approach to working with and regulating public organisations in June 2022, which we call the ‘Public Sector Approach’ (PSA). To assist in understanding both impact and learning from the trial, a monitoring and review plan was established that included a post-implementation review.

The purpose of the post-implementation review report is to present robust evidence on impact and learning from the trial to inform the ICO’s future decisions on regulating public organisations. The overall approach to the review has been theory based and employed mixed methods. This resulted in a broad evidence base to underpin the review’s findings, but one that also presented some challenges which should be kept in mind when considering the findings.

The evidence presented in the review shows that the PSA was an ambitious and challenging trial to deliver over two years with a limited lead-in time. The trial's outcome wasn't a straightforward success or failure. Instead, it was mixed with notable achievements, areas with more to do, unexpected challenges, and unintended consequences.