Re: First offence
... As it is a first offence then it is likely that the ICO will not issue a fine to the ICO ....
Nonsense! As the formal body enforcing the DPA, the ICO ought to know better, and be subject to much higher standards than the general public. Indeed, it made exactly this point when fining a financial organisation recently for having a laptop stolen which had unencrypted personal data on it.
I suggest that the ICO fines the ICO a sum equal to its ENTIRE assets. That will show that the DPA is not to be trifled with...
Biting the hand that feeds IT
