United Kingdom: First-tier Tribunal of General Regulatory Chamber ruling upholding Information Commissioner’s fine against TikTok (No. 2025 UKFTT 00798 GRC)

On 4 July 2025, the UK First-tier Tribunal (General Regulatory Chamber) ruled in favour of the Information Commissioner’s Office (ICO) on a preliminary issue concerning the regulator’s power to take enforcement action against online platforms hosting user-generated content. The ruling applies to platforms processing personal data, specifically TikTok, which had been fined GBP 12.7 million by the ICO in April 2023 for breaching data protection law, including the unlawful processing of children’s personal data. TikTok argued that its processing fell under the special purposes exemption, covering journalistic, academic, artistic, or literary activities, under the Data Protection Act 2018, and that the ICO lacked authority to impose the penalty without prior Court approval. The Tribunal rejected this argument, finding that providing the TikTok service does not constitute processing for the special purposes, allowing the ICO’s enforcement action to proceed while TikTok’s substantive appeal continues.