Precedent corpus / ICO (United Kingdom)
TikTok Information Technologies UK Limited and TikTok Inc.
ICO (United Kingdom) case tiktok-2023-04, decided . GBP 12.7M.
An appeal is pending, or its outcome is not on the public record. Not final.
Upper Tribunal dismissed TikTok's appeal on 28 July 2026 ([2026] UKUT 277 (AAC)) and remitted the substantive issues to the First-tier Tribunal. The GBP 12.7M penalty stands but is not final. Source
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
Between May 2018 and July 2020, TikTok processed the personal data of up to 1.4 million UK children under 13 who used the platform without parental consent; failed to provide adequate information to users about how their data would be collected, used and shared; and failed to ensure the personal data of UK users was processed lawfully, fairly and in a transparent manner - breaching Articles 5(1)(a), 8, 12 and 13 UK GDPR.
Primary source
Regulator-owned URL. Quote this in legal briefs and academic citations.
https://ico.org.uk/action-weve-taken/enforcement/2023/05/tiktok/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/20260806010552/https://ico.org.uk/action-weve-taken/enforcement/2023/05/tiktok/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 12.7M; the EUR figure is our own conversion at the enforcement-date FX rate, has no regulator source, and is approximate. Penalty notice PDF: ico.org.uk/media2/migrated/4025182/tiktok-mpn.pdf. Cite for the children's- data precedent under UK GDPR, parallel to the DPC's TikTok IN-21-9-1 EU-level enforcement.
Verification trail
Checked against the primary source on 27th August 2026. Next review 27th February 2027.
Cite this case
@misc{consentmark-precedent-ico-tiktok-2023-04,
author = {{ConsentMark}},
year = {2023},
title = {ICO (United Kingdom) tiktok-2023-04 - TikTok Information Technologies UK Limited and TikTok Inc.},
howpublished = {\url{https://www.consentmark.com/precedent/ico-tiktok-2023-04}},
note = {ConsentMark methodology v7.8.1}
}ConsentMark. (2023, April 4). ICO (United Kingdom) tiktok-2023-04 - TikTok Information Technologies UK Limited and TikTok Inc.. Methodology v7.8.1. https://www.consentmark.com/precedent/ico-tiktok-2023-04[ICO (United Kingdom) tiktok-2023-04 - TikTok Information Technologies UK Limited and TikTok Inc. - ConsentMark](https://www.consentmark.com/precedent/ico-tiktok-2023-04)ICO (United Kingdom) tiktok-2023-04 - TikTok Information Technologies UK Limited and TikTok Inc. - ConsentMark, 2023-04-04, methodology v7.8.1, https://www.consentmark.com/precedent/ico-tiktok-2023-04