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Ensuring Data Protection Compliance When Sending Emails

September 22, 2023 | By: Joanne Gill

In today's digital age, email communication is an integral part of daily business operations. However, it's essential to recognise that mishandling emails can lead to data breaches, compromising the privacy and security of personal data and confidential information. The Information Commissioner's Office (ICO) has highlighted the improper use of the 'BCC' (Blind Carbon Copy) field as one of the top data breach issues reported each year. This article aims to provide guidance, which we have taken from the ICO, on when and how to use the 'BCC' field effectively, especially when dealing with sensitive personal information.

Understanding the 'BCC' Field

When you use the 'BCC' field to send an email, the recipients cannot see each other's email addresses. This can be a useful tool when sending emails to multiple recipients, particularly if the information shared is not sensitive or confidential, and there is minimal risk involved. However, when dealing with emails that may reveal sensitive information about the recipients, you should carefully consider alternative, more secure methods.

Assessing the Risk When Sending E-mails (GDPR)

Before hitting the send button on an email, it's crucial to assess the potential risks involved. If your email contains sensitive personal information, think twice about using 'BCC.' If you are going to use BCC. then ensure you have done so and not accidentally enabled CC. which would then reveal all recipients email addresses.

Consider the following safeguards;

1. Implement alerting rules

You could set up rules in your email system to enhance email security. These rules could provide alerts and warnings to email senders when they use the 'Carbon Copy' (CC) field. This will help prevent accidental disclosure of email addresses when the sender actually intended to use BCC.

2. Addition of an email delay

You could consider adding a delay to your emails. This would then allow time for errors to be corrected before the email is actually sent. It would provide a safety net for catching any potential mistakes before they reach the recipients.

3. Disable auto-complete on email addresses

Consider turning off the auto-complete email function in your email system. This prevents the system from suggesting email addresses in the recipient's box based on memory which would then reduce the chances of selecting the wrong recipient.

4. Utilise NCSC email security check tool

The National Cyber Security Centre (NCSC) provides an email security check tool that helps you assess the security of your email communications. You could look to incorporate this tool into your email procedures to enhance the security.

Legal Obligations

Under data protection law, organisations are obligated to implement appropriate technical and organisational measures to ensure the safety and confidentiality of personal information. It is crucial to safeguard personal data and prevent its inappropriate disclosure to unauthorised parties.

For organisations that handle and share substantial amounts of data, including sensitive personal information, alternative secure means of communication should be considered. Bulk email services can be a suitable option, as they reduce the risk of unintentional information sharing.

Policies and Training on Email Communications

In addition to technical measures, organisations should establish comprehensive policies and provide training for staff regarding email communications. Staff members must be aware of the risks associated with email and should understand how to handle sensitive information correctly.


In summary, the use of the 'BCC' field in email communication can be a valuable tool for maintaining data privacy. However, it should be used judiciously, particularly when handling sensitive personal information. Always assess the potential risks, and consider implementing additional security measures, policies, and staff training to ensure data protection compliance.

At Wirehouse Employer Services, we understand the importance of data protection compliance in the modern business landscape. Our guidance in this article is based directly upon advice from the ICO, and we encourage our clients to take proactive steps to protect sensitive information when using email communication. If you have any questions or require further assistance with data protection matters, please do not hesitate to reach out to our expert team. Your data security is our priority.

About the Author
Joanne Gill
Joanne Gill
Joanne Gill, Author at Wirehouse Employer Services

Our Employment Law Consultancy Lead Joanne initially followed a consultancy route after qualifying with her law degree, to allow her to be more hands on and work with businesses from a commercial point of view as opposed to just a legal focus. She then ventured to in-house HR, to experience first-hand the issues businesses have when the law doesn’t fit with commercial realities. This has given Joanne the breadth of experience to be able to offer more open-minded advice to Wirehouse clients since moving back to consultancy. Additionally, she has also undertaken qualifications to enable her to assist with the creation and expansion of Wirehouse’s GDPR service.

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