UK ICO criminal caution — London Clinic insider accessed Princess of Wales medical records

The UK Information Commissioner's Office closed a two-year criminal investigation into the deliberate misuse of Catherine, Princess of Wales' medical records at The London Clinic, issuing a formal caution to a former staff member under s.170(5) of the Data Protection Act 2018 (ICO, 2026-06; Infosecurity Magazine, 2026-06-18). Section 170 — unlawful obtaining/disclosing of personal data, carrying up to two years' imprisonment — is pursued under the ICO's own criminal-prosecution authority, distinct from its civil UK GDPR fine regime; the s.170(5) caution requires an admission of guilt. The ICO found no evidence records were sold, treated the offer to disclose for financial gain as the aggravating element, and concluded the clinic's own information-governance arrangements did not warrant regulatory action. Defender takeaway: this is a textbook clinical-insider pattern — privileged Electronic Patient Record access, a high-profile data subject creating monetisation incentive, opportunistic abuse. Comparable Swiss and EU controllers face criminal exposure too (Swiss DPA Art. 60; GDPR Art. 84 member-state criminal competence). Detection posture: alert on EPR accesses outside an accessor's assigned care team (RBAC-violation hunting on access-audit logs, T1078 legitimate-access abuse), which the NHS IG Toolkit and equivalents already mandate logging for.