Partner Joanna Ludlam on the Broader Implications of the TikTok Data Privacy Ruling in City AM

Partner Joanna Ludlam was quoted in City AM on the Upper Tribunal's ruling upholding the ICO's £12.7 million fine against TikTok for unlawfully processing children's data.

The Tribunal rejected TikTok's argument that its processing of under-13s' data fell within the GDPR's "special purposes" exemption for artistic content, finding the platform had no way of verifying the content was used for that purpose.

Joanna noted the ruling's significance beyond TikTok itself:

"This ruling is likely to be relevant to other platforms advancing similar arguments. It lands at a moment when regulators are under real pressure to act quickly on children's data, with the Online Safety Act regime now sitting alongside data protection law."

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Joanna is Chair of the London Public Law and Crisis Management Practice, Co-Chair of the firm's Global Hearing Preparation and Global Crisis Management and Strategic Risk practices, and Co-Chair of the firm's Investigations Department. She advises major corporations, regulators, and public bodies on complex matters spanning administrative and public law, regulatory investigations and litigation, and data regulatory defense.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Partner Joanna Ludlam on the Broader Implications of the TikTok Data Privacy Ruling in City AM

Partner Joanna Ludlam was quoted in City AM on the Upper Tribunal's ruling upholding the ICO's £12.7 million fine against TikTok for unlawfully processing children's data.

The Tribunal rejected TikTok's argument that its processing of under-13s' data fell within the GDPR's "special purposes" exemption for artistic content, finding the platform had no way of verifying the content was used for that purpose.

Joanna noted the ruling's significance beyond TikTok itself:

"This ruling is likely to be relevant to other platforms advancing similar arguments. It lands at a moment when regulators are under real pressure to act quickly on children's data, with the Online Safety Act regime now sitting alongside data protection law."

Read More

Joanna is Chair of the London Public Law and Crisis Management Practice, Co-Chair of the firm's Global Hearing Preparation and Global Crisis Management and Strategic Risk practices, and Co-Chair of the firm's Investigations Department. She advises major corporations, regulators, and public bodies on complex matters spanning administrative and public law, regulatory investigations and litigation, and data regulatory defense.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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