Financial Reporting Council ...

 What is the Financial Reporting Council?

The Financial Reporting Council (FRC) is the UK’s independent regulator of corporate governance, financial reporting, audit and the actuarial profession. In 2019, amid criticisms over the body’s performance, the government decided to replace the FRC with a new Audit, Reporting and Governance Authority (ARGA). But the government reversed this decision in January 2026, despite introducing the necessary legislation in the King’s Speech in 2024.

What does the FRC do?

The FRC was originally established in 1990 with the principal aim of promoting best practice in financial reporting.¹  Over time, its remit has expanded, and its stated purpose is now to serve the public interest by setting high standards of corporate governance, reporting, auditing and actuarial work, and by holding to account those responsible for delivering them.²  In practice, its main work is in overseeing the audit, accounting and actuarial professions, and corporate governance.

The FRC sets the eligibility criteria, and technical and ethical standards, for those approved to carry out the statutory audit of an organisation’s annual accounts in the UK.³  It also maintains, or requires others to maintain, various registers including of those approved to audit public interest or local bodies.⁴

It also issues accounting standards and clarifies conflicting interpretations of those standards. It oversees self-regulation conducted by various professional accounting bodies and monitors compliance with accounting and legal requirements, for example when companies issue directors’ reports.⁵  Its accounting standards are also applicable in Ireland.⁶

The FRC’s role is similar for the actuarial profession – setting standards, overseeing professional bodies and providing an independent investigation and discipline scheme for matters potentially affecting the public interest.⁷

Finally, it oversees corporate governance by setting and monitoring the UK Corporate Governance Code (which applies to companies listed in the UK and Ireland) and the Stewardship Code (which applies to institutional investors in the UK).⁸

What enforcement powers does the FRC have?

The FRC relies on a combination of statutory powers and non-statutory agreements with various other organisations – especially professional bodies – to achieves its aims. In some areas, particularly oversight of the actuarial profession and local authority audit, its concrete powers have been described as “limited or even non-existent”.⁹

It has powers to investigate misconduct by statutory auditors or audit firms and can impose sanctions ranging from a public statement that a breach has been committed to financial penalties and prohibitions from working.¹⁰  It can also take action against members of the professional accounting bodies – individuals or firms – as well as individual actuaries who are members of the Institute and Faculty of Actuaries (IFoA). But the FRC currently has no powers to investigate, take enforcement action or impose sanctions on individuals, including directors, who are not members of these bodies, and its jurisdiction over actuaries relies on agreement with the IFoA.¹¹

How is the FRC structured?

The FRC is a company limited by guarantee¹² , but is also classified as an executive non-departmental public body of the Department of Business and Trade¹³ , and since 2019 its board members have been appointed by the business secretary.¹⁴  It is funded through obligatory contributions from professional bodies and voluntary contributions from private companies, pension schemes and insurance companies.¹⁵

What is the future of the FRC?

Following high-profile auditing and accounting scandals including the collapse of Carillion, the FRC was heavily criticised by the business select committee, which said that its “weak response” contributed to a “crisis of trust in audit”.¹⁶

An independent review by Sir John Kingman in 2018 found it to be “an institution constructed in a different era – a rather ramshackle house, cobbled together with all sorts of extensions over time” and highlighted its lack of a strong statutory foundation and limited powers.¹⁷ 

More - 
https://www.instituteforgovernment.org.uk/explainer/financial-reporting-council

Is Data Still ‘Personal’ If The Recipient Cannot Identify The Data Subject?

Data protection practitioners know that the first question to ask when considering their organisation’s data protection obligations in relation to any data is: “Is it personal data?” 

The Court of Appeal recently handed down a decision which gives useful judicial guidance on the definition of ‘personal data’ under UK data protection law and the responsibility on organisations to keep personal data secure.    

DSG Retail Limited v The Information Commissioner [2026] EWCA Civ 140 is concerned with events from 2017 and 2018 when the old Data Protection Act 1998 (DPA 1998) was in force. As such the judgement is persuasive rather than binding on UK courts when deciding on issues under the current law; namely the UK GDPR and Data Protection Act 2018. 

The background to the case is that, in 2017, DSG Retail Limited (the parent company of Dixons and Currys PC World) (DSG) suffered a cyberattack targeting point of sale systems in all its shops. Over a nine month period, attackers deployed malware to scrape transaction level card data and attempted to exfiltrate the captured information. More than 5.6 million payment cards were affected; though the majority consisted only of the 16-digit payment card numbers and expiry dates (together referred to as ‘EMV data’). Crucially, the attackers did not obtain any information that could directly identify the cardholders. 

In 2020, the ICO fined DSG £500,000 for breach of the data security principle. 
This was the maximum fine under the DPA 1998. There then followed a series of appeals. The First Tier Tribunal (FTT) upheld the ICO’s findings but reduced the fine by half.  

The Upper Tribunal (UT) in setting aside the FTT’s decision held that the data security principle under the DPA 1998 applies to only to ‘personal data’ i.e. information about living, identifiable, individuals. The data in question, EMV data, did not constitute ‘personal data’ from the attackers’ perspective because the attackers could not link it to specific individuals. As a result, the UT held that DSG did not have any security obligations with respect to such data.  

Following an appeal by the ICO, the Court of Appeal (CoA) has now overturned the UT’s ruling. The CoA held that the Data Controller (in this case DSG) is required to comply with the data security principle under the DPA 1998 with respect to data that is ‘personal’ from the perspective of the Data Controller,  regardless of whether the data might not be personal ‘in the hands of’ or ‘from the perspective’ of any other person. 

The CoA considered it implausible that (absent an explicit statement) Parliament intended to limit the scope of the data security duty so that a Data Controller would have no obligation to protect some parts of the data provided by the Data Subject. The CoA also noted the potential consequences of a contrary reading; there would be no obligation for the Data Controller to protect data when a third party would be unable to identify the Data Subject from that data. In the Court’s view, third-party interference with data, even where the attacker is unable to identify the Data Subjects, can still be harmful. Moreover, the Court found it impractical to put Data Controllers in a position where, in determining their data security obligations, they would need to assess whether attackers could
re-identify individuals via ‘jigsaw’ techniques. 

More - 
https://actnowtraining.blog/2026/03/02/is-data-still-personal-if-the-recipient-cannot-identify-the-data-subject/

Legal challenge launched against government SEND proposals that “significantly weaken the legal rights of children and young people”

Well, that didn’t take long. It’s less than a week since the Government published long-awaited proposals for “reforming” the SEND system, and the first steps have already been taken in a legal challenge against the Secretary of State for Education.

If successful, this could force ministers to publish an amended version of the consultation to add more information about what is proposed, as well as specific questions on some key changes. It could also mean extending the consultation period.

Consultation lawfulness questioned

The family of Jessica Hayhurst, a little girl with complex special educational needs, has instructed lawyers to send a formal letter before legal action to Bridget Phillipson. The letter questions the lawfulness of the consultation process on SEND reform in relation to two things:

1. The proposed weakening of SEND Tribunal powers, and
2. A shift in legal duties from local authorities to schools.

The family is being represented by Polly Sweeney and Bethany Parr from Rook Irwin Sweeney, which is funding the claim through its Social Justice Fund. Barrister Steve Broach KC is providing pro bono support.

The letter says:

“Many of the proposals being put forward in the White Paper will result in parents and children losing important existing legal rights”.

As we outlined in our first post on the Schools White Paper and SEND proposals, the 132-page consultation paper invites views and responses to 40 specific questions from anyone with an interest in the plans by 18^th May 2026. The questions cover things such as how children can be supported in the new proposed ‘layers’ and how “Inclusion Bases” should work.

More - 
https://www.specialneedsjungle.com/legal-challenge-against-send-proposals-significantly-weaken-legal-rights-children/

Inquiry hears how lack of accountability for disabled people’s Covid deaths caused lasting harm...

The lack of accountability for the tens of thousands of Covid-related deaths of disabled people receiving care in their own homes and residential settings has caused lasting harm, the UK Covid inquiry has been told.

In their opening written submission to the 10^th and final module of the UK Covid-19 Inquiry – on the pandemic’s impact on society – three national disabled people’s organisations (DPOs) said many deaths remained un-investigated, particularly in England and Wales.

Despite tens of thousands of Covid-related deaths of disabled people who had been reliant on care or health workers, the number of all deaths reported to coroners in England and Wales in 2020 was the lowest since 1995, partly because of easements to requirements around the registration of deaths and reporting by medical practitioners.

Among the matters left under-investigated was whether the use of inappropriate “do not attempt cardiopulmonary resuscitation” notices and “clinical frailty score” assessments led to preventable deaths.

In Scotland, there was an increase in reported deaths because of the work of the Covid-19 Deaths Investigation Team, although this was limited to deaths linked to employment and residential care.

The three national DPOs – Disability Rights UK, Inclusion Scotland and Disability Action Northern Ireland – told the inquiry in their opening oral submission last week that disabled people were “far more likely to die from Covid-19 than non-disabled people”, and people with Down’s syndrome could have been more than 30 times more likely to die from the virus.

But they said there was “never a point in the pandemic when government and public authorities properly scrutinised the detail of these deaths in terms of their relevant impairments and circumstances, let alone examine their preventability”.

They told the inquiry, through their barrister, Kate Beattie: “Rather than continuing or even enhancing the reporting and investigation of deaths of disabled people, at a moment when people were dying in dependent situations outside hospitals in numbers unknown in living memory, the formal reporting of deaths reached a historic low.

“The various health and care monitoring bodies did not necessarily inspect and did not prioritise site visits, and if deaths were reported, the holding of inquests was minimised without the anxious scrutiny which was warranted by these unparalleled circumstances.

“The outcome, as recounted by the Covid Bereaved Families for Justice and others, was a failure of accountability to disabled people who were bereaved, to non-disabled people who were grieving the deaths of their disabled loved ones, and to disabled people more generally.”

She added: “The legacy is a terrible human cost for those denied the opportunity to establish truth so that a person can properly begin to grieve it.”

The DPOs also told the inquiry that the government needed to “acknowledge the importance of disabled people’s rights and the failure to do enough to protect those rights” by incorporating the UN Convention on the Rights of Persons with Disabilities into UK law and introducing new laws that would “embed accessibility across all aspects of life”.

And they stressed the importance of “effective and properly funded co-production” of policy with disabled people, intersectional organisations and DPOs, as well as “far greater understanding of the social model and of intersectional experiences that mean that certain societal groups are far more marginalised than others”.

Giving oral evidence to the inquiry this week, Dr Pauline Nolan, head of participation and policy at Inclusion Scotland, said that a survey by her organisation in April 2020 showed that 30 per cent of respondents said their usual social care support had been “either stopped completely or reduced, sometimes overnight or without any warning” in the early months of the pandemic.

And, she said, disabled people had been “really anxious about not getting social care support recovered after the pandemic because they were seen to manage”.

She said that at least 28,000 recipients of domiciliary care in England and Scotland had died by May 2021..

More - 
https://www.disabilitynewsservice.com/inquiry-hears-how-lack-of-accountability-for-disabled-peoples-covid-deaths-caused-lasting-harm/

Gwynedd Council - Leader Of The Gang...?

In November, 2021, Neil Foden, headteacher at Ysgol Dyffryn Nantlle in Penygroes wrote to parents informing that any child with a debt of 2p would be refused school meals. This caused a national furore with interventions from Marcus Rashford and blogger Simon Harris (men behaving dadly)

The headteacher blamed the decision on his council bosses who he claims 'threw him under a bus' -
https://www.bbc.co.uk/news/uk-wales-59341464
"All I did was to pass on the authority's message to parents."

Gwynedd Council blamed "lack of clarity" from its education department on school food debt policy -
https://www.walesonline.co.uk/news/education/council-apologises-school-meal-debt-22153658

Councillors of Gwynedd's Education and Economy Scrutiny Committee challenged the Head of Education, Garem Jackson, for an explanation. He did not provide one but promised an update for the next meeting.

Two months later, a video was posted online that appears to show Neil Foden grabbing a pupil by the scruff of the neck -
https://www.walesonline.co.uk/news/education/head-teacher-filmed-appearing-grab-22967578

At the next scrutiny meeting, Mr Jackson failed to answer the committees previous concerns and was also unwilling to respond to the latest incident. Once again, promising to get the full facts and return with an update for councillors.
There is no record of Mr Jackson updating the committee on either incident...

Mr Foden has a history of controversy. In 2018, a Biology teacher was awarded £8,000 compensation after an 'outrageous' suspension by the Ysgol Friars headteacher -
The tribunal was convinced Mr Foden had at one stage been “looking for an excuse to make things difficult for the claimant”.
https://www.dailypost.co.uk/news/biology-teacher-awarded-8000-compensation-14867550

Also -
“We developed a particular view about the evidence given by Mr Foden which undermined his credibility and/or reliability as a witness.”
https://www.dailypost.co.uk/news/north-wales-news/autocratic-gwynedd-headmaster-included-malpractice-14853841
How is this not perjury?

In 2020, he was found guilty of unacceptable professional conduct by the Education Workforce Council.
It was proved that Mr Foden treated a third teacher unfairly when providing a reference in 2016 in which he said he was facing an allegation of malpractice when, in fact, the teacher had been cleared.
https://www.bbc.co.uk/news/uk-wales-54300055

The panel heard evidence that included -
"I felt victimised by Neil Foden due to the way he operated. You were either in his gang or you were not," person D told the panel. He claimed he was never interviewed by school governors and that Mr Foden's daughter had investigated the allegations against him.
https://www.bbc.co.uk/news/uk-wales-51710557

The teacher claimed Mr Foden was looking to "pressurise" him after he made whistleblowing complaints over erroneous submissions of exam results by his department boss.
Person D said he made the whistleblowing complaints in 2014 because pupils had been "awarded an exam pass" and he was initially concerned it was an "administrative error".

However, he said the evidence had been moved for the five pupils concerned. "The evidence had been removed from a computer file. It had taken a year and a quarter for the exam board to be told."
Person D said he and two other concerned teachers were not interviewed about the exam concerns until "four to six months later".
https://www.dailypost.co.uk/news/north-wales-news/headmaster-victimised-teacher-who-blew-17850450

The delay in interviewing the teachers will affect any legal process as there is a very short window to lodge complaints and/or take legal action. After one year, it is presumed that the exam board would dismiss any concerns as out of time...
Mr Foden is also Head of Ysgol Friars in Bangor.

Perhaps the scrutiny committee could remind the Head of Education of his promise to report on the incidents and also ask for an update on the two teachers believed to have been suspended on full pay for 9 years...

In 2014, the council's safeguarding team began an investigation alongside north wales police.. It did not go well. In 2016, the CPS threw out the case after they did a deep dive of the 'evidence'. 

A spokesman for the council said -
"This process concluded with the CPS deciding not to proceed with any prosecutions. The council is currently carrying out its own subsequent internal investigation into the matter and as a result the individuals remain suspended from their posts.”
https://web.archive.org/web/20180729072902/https://www.walesonline.co.uk/news/wales-news/welsh-councils-paid-9m-staff-14876849

Gwynedd council also paid over £800,000 of public money to north wales police. For what...?
The costs of this case, including the legal fees, must be approaching 2 million pounds - if not more... 

An FOI seeking information on the matter was shut down by the monitoring officer who simply ignored the request for an internal review. The next step in the legal process - a complaint to the ICO - usually requires an internal review to have been undertaken. Regardless, the ICO can only 'advise' the council to release information. Gwynedd council have ignored the 'advice' of the ICO in the past...

Questions to the integrity and professionalism of the safeguarding team remain. The senior safeguarding officer for Gwynedd has not been seen at a council meeting since 2019 when he was called out for deceiving the care scrutiny committee in another case.

Something is so very wrong within Gwynedd council...