2017

The UK's Information Commissioner's Office recently updated its code of practice for privacy notices in an effort to help companies comply with the “good practice” recommendations in the Code.
 
The ICO has recommended that businesses inquire and test before launching any privacy notice language, as well as construct a layered notice, being cognizant of third party transfers and remaining compliant with the GDPR.
 
In addition, the ICO encourages businesses to use a combination technique when presenting privacy information, including front page notice of unexpected use, a just-in-time notice, separate opt-in boxes for different uses, dashboards, and icons, symbols and videos.

Uber recently had its licence to operate in London pulled by Transport for London (TfL) after it was found to “fail to report alleged criminal offences carried out by its drivers and a lax attitude towards background checks and obtaining medical certificates”.
 
In early September, it was found that up to 13,000 Uber drivers had insufficient background checks and some were obtaining falsified medical certificates.
 
The company has the right to appeal and can continue to operate until it has exhausted the appeals process. As a result, 40,000 drivers could lose their jobs.

On 26 October 2017, the Treasury published an update to the National Risk Assessment (NRA) of money laundering and terrorist financing.

The NRA is the Government's assessment of the key Money Laundering (ML) and terrorist financing threats facing the UK including the susceptibility of the sectors to money laundering and terrorist financing.

Key findings from the report include:
- the criminal exploitation of banks, professional and financial services and cash remain the greatest areas of money laundering risk to the UK
- cash remains the preferred method for terrorists to move funds through and out of the country
- a wide-ranging set of reforms by the government, like introducing the ability to investigate suspicious asset trails and to crack down on illicit finance over recent years are starting to take effect.

We encourage firms to review the document alongside other guidance such as the FCA Guide for Firms and JMLSG with a view to understanding how the risks identified could have an impact on them.