Eight years in the data protection function, most recently at a top-five UK bank. Now running the specialist consultancy I would have wanted to engage when I was on the other side of the table — built deliberately, with the discipline of senior judgement supported by careful, modern tooling.
Banking is the most heavily scrutinised data environment in the UK economy. The volume is enormous, the regulators are demanding, the consequences of error are public, and the standard of evidence is unforgiving. You learn to design processes that survive an FCA examination, an ICO audit, and an internal three-lines-of-defence review in the same week.
I spent eight years inside that environment. High-volume DSAR handling. Dual FCA and ICO reporting. International transfers under successive iterations of the standard contractual clauses. Breach response under genuine regulatory scrutiny. The discipline required at that scale is not theoretical — it has to work, on Tuesday afternoon, when something has gone wrong.
Most SMEs do not need that machinery. They need access to the judgement that comes from having operated it. Someone who can read a DPIA and tell them which of the ICO's eleven Accountability Framework areas matter for their organisation this quarter. Someone who has handled enough breaches to recognise which ones genuinely require notification and which are noise.
That is what Varnham & Co. is built to deliver. Senior judgement, applied to organisations that cannot reasonably hire it in-house, in a relationship structured to feel like an internal appointment rather than an external supplier. Banking-grade depth at the scale and price points UK SMEs can support.
The economics that make this possible rest on a deliberate choice about how the consultancy is built. The substantive judgement work — the gap analyses, the advice notes, the signed assessments — is personally mine. The administrative and structured-output work — assessment scoring against the Accountability Framework, documentation assembly, regulatory monitoring, the first-pass scaffolding that every consultancy spends time on — is handled by carefully-deployed AI tooling, within frameworks I design and maintain. The judgement is always mine; the leverage is in the operating model around it.
The same banking-sector discipline that informs the substantive advice is what qualifies the consultancy to deploy these tools safely and lawfully. A data protection consultancy using AI must be exemplary in its own AI use, with personal accountability across both the substance and the operating model. That is the standard I hold myself to, and the standard a sophisticated SME ought to expect from anyone advising them on data protection in 2026.
Data protection is a profession in which credentials matter, both to regulators and to clients evaluating provider seriousness. These are the credentials held — and what each one means.
The IAPP's flagship certification covering the legal and regulatory framework of European data protection — UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act 2025, and the regulatory bodies that enforce them. The qualification regulators expect a senior data protection adviser to hold.
The IAPP certification covering the operational side — how to build, run, and measure a privacy programme inside an organisation. Pairs with CIPP/E to demonstrate both legal knowledge and the ability to apply it operationally.
High-volume DSAR handling, FCA and ICO reporting, international transfer assessments, breach response, three-lines-of-defence governance. The senior bank role is the most recent chapter of an eight-year career in the function — and the foundation of the standards Varnham & Co. holds itself to.
A Derbyshire-based therapy charity. Direct experience of the data protection obligations that fall on charity boards — vulnerable beneficiary data, safeguarding overlays, funder reporting, and the trustee duty to ensure compliance is substantive rather than paper-deep.
Direct experience of how data protection obligations land in education — children's data under the ICO's Age Appropriate Design Code, safeguarding records, parental consent, SEN data sharing with local authorities. Governance from the inside.
You work with me directly, not a rotating pool of advisers. I learn your data flows, your systems, and your risk profile over time. The person who agrees the engagement is the person who attends your governance meetings.
Every assessment is structured around the ICO's Accountability Framework — the standard the regulator uses to assess compliance maturity. The eleven areas (AF-01 to AF-11) are the structural backbone of every engagement.
I have implemented data protection in large, complex organisations where pragmatism matters. The advice works in the real world — it knows where the genuine risks lie and where proportionate measures are sufficient.
The administrative side of the work is handled by AI tooling within frameworks I design and maintain. This is disclosed openly because it is the structural choice that makes banking-grade depth economically possible at SME price points. The substantive judgement remains personal.
Policies, procedures, and reports are written in clear English for the people who actually use them — not in regulatory jargon. The audit trail still works, but the day-to-day documentation reads as a useful tool.
From day one of an engagement, every deliverable is filed, version-controlled, and stored in a structured compliance library. If the ICO asks a question, the evidence base is already in place — not constructed under deadline.
An SME engaging a DPO with banking-sector experience receives two things that most SME-focused providers cannot deliver.
First, exposure to the hardest compliance problems. If you have managed international data transfers across a global banking group, advising a UK technology company on a single cloud-hosting arrangement is a matter of applying familiar principles at simpler scale.
Second, a compliance standard calibrated to genuine regulatory expectations. The bar the ICO actually applies is known here because it has been encountered — not theoretically, but in practice. This does not mean over-engineering compliance for SMEs. It means knowing where the real risks lie and where proportionate measures are sufficient.
An honest read of where you stand, what your obligations actually require, and what the right next step looks like — even if that next step is no engagement at all. The intake form is the way in.
The form takes under two minutes. No automated marketing. No follow-up sequence. No surprises.
Your name, your organisation, and the nature of your enquiry. That is what is needed to respond properly.