Precedent corpus / ICO (United Kingdom)
Easylife Ltd
ICO (United Kingdom) case easylife-2022-10, decided . GBP 1.4M.
We have not checked whether this decision was appealed. This is not a statement that no appeal exists.
No ConsentMark grade rests on this decision. It is published here because it is relevant enforcement, not because it bears on what a browser does before consent.
What the regulator decided
Easylife profiled customers based on items purchased from its non-health catalogue to make assumptions about their medical conditions and then used those profiles to market health products, processing special- category data within Article 9 UK GDPR without an Article 9(2) lawful basis; also made 1,345,732 unsolicited direct marketing calls to individuals registered with the Telephone Preference Service in breach of regulation 21 PECR.
Primary source
Regulator-owned URL. Quote this in legal briefs and academic citations.
https://ico.org.uk/action-weve-taken/enforcement/easylife-limited-mpn/Archived snapshot
Wayback Machine snapshot of the primary source. Use this when the regulator URL might be refactored or expire.
https://web.archive.org/web/20240617084322/https://ico.org.uk/action-weve-taken/enforcement/easylife-limited-mpn/ConsentMark interpretation
Operator-readable note on how this case shapes the ConsentMark scanner narrative. Not a legal opinion; cites the primary source.
Native fine GBP 1.35M (combined GBP 1.35M GDPR penalty and GBP 130k PECR penalty). Cite when the scanner narrative needs the precedent that inferring health-related profiles from on-site behaviour triggers Article 9 even if the inputs are not themselves health data - directly relevant to ad-tech audiences built on purchase signals.
Verification trail
Checked against the primary source on 26th May 2026. Next review 26th November 2026.
Cite this case
@misc{consentmark-precedent-ico-easylife-2022-10,
author = {{ConsentMark}},
year = {2022},
title = {ICO (United Kingdom) easylife-2022-10 - Easylife Ltd},
howpublished = {\url{https://www.consentmark.com/precedent/ico-easylife-2022-10}},
note = {ConsentMark methodology v7.8.1}
}ConsentMark. (2022, October 4). ICO (United Kingdom) easylife-2022-10 - Easylife Ltd. Methodology v7.8.1. https://www.consentmark.com/precedent/ico-easylife-2022-10[ICO (United Kingdom) easylife-2022-10 - Easylife Ltd - ConsentMark](https://www.consentmark.com/precedent/ico-easylife-2022-10)ICO (United Kingdom) easylife-2022-10 - Easylife Ltd - ConsentMark, 2022-10-04, methodology v7.8.1, https://www.consentmark.com/precedent/ico-easylife-2022-10