Why your supporters are wealthier than you expect. Course details.

New ICO guidance on sending bulk emails published

Melanie May | 4 September 2023 | News

A woman's hand on a computer mouse, also holding a pen. By Vojtech Okenka on Pexels

Charities have been warned by the Information Commissioner’s Office to use alternatives to the BCC email function when sending communications including sensitive personal information.

The warming follows what the ICO calls ‘a catalogue of business blunders’ and the publication of new guidance.

The ICO says the charity sector is the fifth biggest offender for BCC breaches, with education first, health second, local government third and retail fourth, and highlights some recent cases. Last month it reprimanded two Northern Irish organisations (not charities) for disclosing people’s information inappropriately via email. And in March the ICO issued a reprimand to NHS Highland for a “serious breach of trust” after a data breach involving those likely to be accessing HIV services. 


Getting Started with TikTok: An Introduction to Fundraising & Supporter Engagement

According to ICO data, failure to use BCC correctly is consistently within the top 10 non-cyber breaches, with nearly a thousand reported since 2019. 

ICO guidance

Under data protection law, organisations must have appropriate technical and organisational measures in place to ensure personal information is kept safe and isn’t inappropriately disclosed to others. 

The ICO says that organisations using and sharing large amounts of data, including sensitive personal information, should consider other secure means to send communications, such as bulk email services, mail merge, or secure data transfer services, so information is not shared with people by mistake.  

Organisations should also consider having appropriate policies in place and training for staff in relation to email communications.  

For non-sensitive communications, it says organisations that use BCC should do so carefully to ensure personal email addresses are not shared inappropriately with other customers, clients, or other organisations. 

Mihaela Jembei, ICO Director of Regulatory Cyber, said: 

“Failure to use BCC correctly in emails is one of the top data breaches reported to us every year – and these breaches can cause real harm, especially where sensitive personal information is involved.


“While BCC can be a useful function, it’s not enough on its own to properly protect people’s personal information. We’re asking organisations to assess the nature of the information and the potential security risks when deciding on the best method to communicate with staff or customers. If organisations are sending any sensitive personal information electronically, they should use alternatives to BCC, such as bulk email services, mail merge, or secure data transfer services.


“This new guidance is part of our commitment to help organisations get email security right. However, where we see negligent behaviour that puts people at risk of harm, we will not hesitate to use the full suite of enforcement tools available to us.”