ICO guidance, purpose limitation: a very different or unexpected purpose probably needs specific consent (Information Commissioner's Office, 'Principle (b): Purpose limitation', updated 23 March 2026)
The ICO's own reading is that sharing personal data for a very different, unexpected purpose probably needs specific consent. A UK holder licensing identifiable records for AI training should expect to need consent or de-identification.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“In general, the new purpose is likely to be incompatible with your original purpose if it: is very different from the original purpose; would be unexpected; or would have an unjustified impact on the people involved. In practice, you're likely to need to ask for specific consent to further use or share people's personal information for this type of purpose.”
Figures it counts in
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Cited in this guide