"However there may be other requirements to report to the subject that are lower than the GDPR high risk threshold. A clear example is the duty of candour on the NHS and embedded in most professional body codes of conduct"
Understood. Professional duties of candour are however equally slippery and open to interpretation. Ones like the GMC are basically focussed on treatment safety and care, and in the sort of case I am talking about can often be summarised as "use your professional judgement" - which rather begs the question.
Certainly anything breach related incident notifiable under the duty in Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 20 must also be notifiable to ICO given the definition therein of a notifiable incident.
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