Precedent corpus / ICO (United Kingdom)

LastPass UK Limited

ICO (United Kingdom) case lastpass-2025-11, decided 2025-11-20. EUR 1,430,000.

What the regulator decided

In August 2022 an attacker compromised the corporate laptop of an EU-based LastPass employee and then a US-based employee's personal laptop used for work, capturing a master credential and accessing the LastPass backup database to take customer names, email addresses, phone numbers and stored website URLs of up to 1.6 million UK customers; LastPass had not implemented appropriate controls around BYOD device usage, breaching Article 5(1)(f) and Article 32(1) UK GDPR.

Primary source

Regulator-owned URL. Quote this in legal briefs and academic citations.

https://ico.org.uk/media2/xfbl1uaa/lastpass-uk-ltd-penalty-notice.pdf

ConsentMark interpretation

Operator-readable note on how this case shapes the ConsentMark scanner narrative. Not a legal opinion; cites the primary source.

EUR amount approximate. The ICO highlighted BYOD-on-personal-devices as the central control failure - LastPass's zero-knowledge vault encryption prevented full credential extraction, but metadata loss alone was sufficient for an Article 32 breach. Cite when a scanner finds analytics or operations administered from personal devices outside a managed endpoint estate.

Verification trail

Verified by
donal
Verified at
2026-05-27
Review due
2026-11-27
Cite this case

Pick the format that matches where you are pasting. The methodology version is preserved in every variant so the citation stays verifiable after future methodology changes.

BibTeX
@misc{consentmark-precedent-ico-lastpass-2025-11,
  author       = {{ConsentMark}},
  year         = {2025},
  title        = {ICO (United Kingdom) lastpass-2025-11 - LastPass UK Limited},
  howpublished = {\url{https://www.consentmark.com/precedent/ico-lastpass-2025-11}},
  note         = {ConsentMark methodology v1.3}
}
APA
ConsentMark. (2025, November 20). ICO (United Kingdom) lastpass-2025-11 - LastPass UK Limited. Methodology v1.3. https://www.consentmark.com/precedent/ico-lastpass-2025-11
Markdown
[ICO (United Kingdom) lastpass-2025-11 - LastPass UK Limited - ConsentMark](https://www.consentmark.com/precedent/ico-lastpass-2025-11)
Plain text
ICO (United Kingdom) lastpass-2025-11 - LastPass UK Limited - ConsentMark, 2025-11-20, methodology v1.3, https://www.consentmark.com/precedent/ico-lastpass-2025-11