Privacy International filed a formal complaint to the UK Information Commissioner on 18 August 2025 alleging that two Home Office automated tools, Identify and Prioritise Immigration Cases (IPIC) and the Electronic Monitoring Review Tool (EMRT), fail to comply with the UK GDPR and the Data Protection Act 2018. The tools appear to inform life-altering decisions including detention, removal and electronic monitoring via GPS tags. The complaint cites evidence from Public Law Project, Duncan Lewis Solicitors and Wilson Solicitors and raises concerns about opaque processing, excessive data collection and retention, inadequate human review and the absence of a required DPIA. PI requests ICO enforcement to halt processing and investigate compliance.
The complaint highlights significant concerns with these tools including the collection, retention, and processing of data presumptively in violation of many of the legal requirements set out in the UK GDPR and the DPA 2018. From PI's perspective, the HO's use of these tools is opaque, lacks a clear and foreseeable justification, processes unjustifiable volumes of personal data, is subject to inadequate human review, and may be adversely impacting migrants who are subject to them.
Had the Home Office carried out a proper Data Protection Impact Assessment (DPIA), as they are legally required to do, these are issues they might have noticed. PI is asking the ICO to issue an enforcement notice to cease all data processing activities, to investigate the HO's use of these tools, to consider their compliance with the GDPR, and to ensure the HO complies with data protection laws.
Collection
[
|
...
]