Next Week on The Open Book Problem: The Subscription Scam That Is Not Quite a Scam
Week 3 of The Open Book Problem has covered the regulatory record in detail.
This week’s podcast episode with Lucy Harper asked why the commercial data broker market has grown across seven years of UK GDPR. The documented answer: the ICO found widespread and systemic failings in 2020, issued an enforcement notice against Experian, lost the appeal in April 2024, and confirmed no further appeal in May 2024. No monetary penalty was imposed.
The companion content this week followed that thread.
Tuesday’s deep-dive put the enforcement record in context: the ICO’s position versus EU comparators, the comparative enforcement gap, and what the market concluded from the Experian outcome.
Wednesday’s analysis from Mauven MacLeod examined the Upper Tribunal judgment specifically, why the timeline of the case matters as a signal to the industry, and what the DUAA’s enhanced powers for the Information Commission may or may not change.
Thursday’s practical guide from Graham covered the process that actually produces results when submitting UK GDPR erasure requests to data brokers: SAR before erasure, documented submissions, day 28 calendar reminders, systematic reappearance tracking, and the ICO complaint record for non-compliant brokers.
Friday’s investigation from Lucy went through the six accountability questions the public record cannot yet satisfactorily answer about ICO oversight of the data broker sector.
Saturday’s opinion made the structural point: data rights that require sustained personal labour to exercise indefinitely are not genuinely universal rights. They are rights for the persistent. That distributional failure needs naming.
What Is Coming Next Week
Episode 4 of The Open Book Problem drops on Monday.
Graham Falkner joins me for The Subscription Scam That Is Not Quite a Scam.
DeleteMe. Incogni. The paid removal industry that has grown precisely because exercising individual rights is too laborious for most people to sustain.
These services are not scams. Some provide a genuine function. But UK users need to understand several things before subscribing.
In August 2025, Deloitte published an independent assurance report verifying Incogni’s claims on broker coverage: 420 or more data brokers covered, recurring removal requests every 60 days for public brokers and every 90 days for private brokers, and over 245 million removals processed. That kind of third-party verification is unusual in this industry and worth understanding.
What neither Deloitte nor any subscription service can verify is coverage of UK-specific upstream sources. Companies House address records and open electoral register exposure require official government processes, not broker opt-out requests. A subscription service cannot fix those sources. And if those sources continue publishing, broker databases will keep refreshing.
We will also cover the two-hour test: what to check before paying anything, what it tells you about whether your problem is upstream, downstream, or both, and how to decide whether a paid service fills a real gap for your specific situation.
The Week Ahead
Monday: Episode 4 with the full podcast and companion article.
Tuesday: Deep-dive on what the major removal services actually cover for UK users, what the Deloitte audit confirms, and where the coverage gap sits.
Wednesday: Graham’s reaction piece on the false confidence problem: why a subscription dashboard that shows removals can hide the fact that the most important exposures were never addressable by the service in the first place.
Thursday: Graham’s practical guide on how to run the two-hour test, in detail, with specific steps for UK directors.
Friday: Lucy’s investigation into what the services charge, what they guarantee, and what a well-informed UK director should ask before signing up.
Saturday: The opinion on why a subscription market for your own legal rights is itself the scandal, not the services that fill the gap.
Episode 4 on Monday.