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A comprehensive, GDPR-equivalent omnibus statute with an identified independent regulator and operative registration regime is in force; residual gaps are narrow (exact territorial-scope pinpoint, exact commencement date of the Alderney 2009 Ordinance).
Sub-modules (5)
Regulator And AuthorityGreen
ODPA is confirmed as the independent supervisory authority for the Bailiwick, including Alderney.
Claims (3):
- Office of the Data Protection Authority — The ODPA is the independent supervisory authority for the Data Protection (Bailiwick of Guernsey) Law, 2017, covering Guernsey, Alderney and Sark.
- Office of the Data Protection Authority (ODPA) — The Bailiwick of Guernsey's data protection regulator, delegated day-to-day regulatory functions by the Data Protection Authority under the Data Protection (Bailiwick of Guernsey) Law, 2017.
- ODPA is the independent supervisory authority under the Data Protection (Bailiwick of Guernsey) Law, 2017.
Act And InstrumentsGreen
Primary instrument is the 2017 Law (in force 25 May 2018), object clause equivalent to GDPR/LED; amended/associated by several ordinances and regulations including an Alderney-specific ePrivacy ordinance.
Claims (2):
- Data Protection (Bailiwick of Guernsey) Law, 2017 — Came into force on 25 May 2018, replacing the 2001 Law and implementing GDPR/LED equivalence across the Bailiwick, including Alderney.
- ODPA announced that annual registration fees (Bailiwick-wide, including Alderney) will rise by more than 4% from 1 January 2027.
Material ScopeAmber
Section 2 'Condition A' confirms automated-means processing is caught; the full text of 'Condition B' (manual filing systems) was not captured in retrieved sources.
Claims (1):
- Data Protection (Bailiwick of Guernsey) Law, 2017, s.39 — Section 39 prohibits all controllers and processors established in the Bailiwick from processing personal data unless registered with the ODPA; failure to comply is a criminal offence.
Territorial ScopeRed
No pinpoint provision equivalent to GDPR Art 3(2) targeting/monitoring test, household exclusion, or Art 27-equivalent representative duty was located for the Bailiwick Law within available sources.
Claims (2):
- Data-protection registration and fee obligations were extended to require Alderney organisations to register with the ODPA from 1 January 2021.
- Data Protection (Bailiwick of Guernsey) Law, 2017, s.111 — An entity is 'established in the Bailiwick', and thus caught by the Law, if it is a Guernsey/Alderney/Sark person, maintains an office/branch/agency or regular practice there, causes processing equipment there to be used other than for transit, or engages in effective and real processing through stable arrangements there.
Regulator Registration And FilingGreen
Annual registration and levy regime in force since 2021 for controllers/processors established in the Bailiwick, with tiered fees and exemptions for charities.
Claims (5):
- The ODPA found the States of Alderney, as controller, breached section 15 of the DPL 2017 (right of access) through inconsistent and excessive redactions of a letter provided to a former Chief Executive in response to a subject-access request.
- Data Protection (Bailiwick of Guernsey) Law, 2017 — The Law differentiates 'authorised jurisdictions' (including EU member states and EC-adequacy countries) from 'unauthorised jurisdictions' for cross-border transfer purposes, applicable Bailiwick-wide including Alderney.
- ODPA announced that annual registration fees (Bailiwick-wide, including Alderney) will rise by more than 4% from 1 January 2027.
- Office of the Data Protection Authority (ODPA) — GBP 62.22 (under 50 employees) or GBP 2,488.80 (50+ employees), a 3.7% RPI-linked increase, effective 1 January 2026; charities/not-for-profits register but pay no fee.
- Data Protection (Bailiwick of Guernsey) Law, 2017, s.39 — Section 39 prohibits all controllers and processors established in the Bailiwick from processing personal data unless registered with the ODPA; failure to comply is a criminal offence.
Regulator & Framework
The Office of the Data Protection Authority is the independent supervisory authority for the purposes of the Data Protection (Bailiwick of Guernsey) Law, 2017, a position it has held since the Law came into force on 25 May 2018. Alderney organisations have been brought within the same registration framework as the rest of the Bailiwick, required to register with the Authority from 1 January 2021.
The Authority has announced that annual registration fees will rise by more than 4% from 1 January 2027, a change that applies Bailiwick-wide and therefore to registered controllers based in Alderney. The announcement was made on 20 October 2026; the increase itself has not yet come into effect and will not apply until the new year. The Authority states that it is funded entirely by registration fees and operates independently of the States of Guernsey, which situates the fee rise as a funding-model adjustment internal to the regulator's own financing rather than a change to the substance of what registered controllers must do.
Whether a separate fee band applies specifically to Alderney-registered organisations, distinct from the general Bailiwick-wide schedule, has not been confirmed and will depend on the detail of the published 2027 fee schedule.
Outlook
Controllers registered in Alderney should plan for the higher registration cost from the start of 2027 while the obligation to register itself remains unchanged. The open question is whether the new schedule treats Alderney organisations identically to the rest of the Bailiwick or introduces any differentiated band; that will only be settled once the Authority publishes the full 2027 fee table.
Sources and claims (9)
- Probable Bailiwick Express — ODPA announced that annual registration fees (Bailiwick-wide, including Alderney) will rise by more than 4% from 1 January 2027. observed
- Probable Bailiwick Express — Office of the Data Protection Authority (ODPA) — GBP 62.22 (under 50 employees) or GBP 2,488.80 (50+ employees), a 3.7% RPI-linked increase, effective 1 January 2026; charities/not-for-profits register but pay no fee. observed
- Confirmed https://www.odpa.gg/ — Office of the Data Protection Authority — The ODPA is the independent supervisory authority for the Data Protection (Bailiwick of Guernsey) Law, 2017, covering Guernsey, Alderney and Sark.
- Confirmed ODPA - The Law — Data Protection (Bailiwick of Guernsey) Law, 2017 — Came into force on 25 May 2018, replacing the 2001 Law and implementing GDPR/LED equivalence across the Bailiwick, including Alderney. observed
- Probable https://www.dlapiperdataprotection.com/index.html?t=law&c=GG — Data Protection (Bailiwick of Guernsey) Law, 2017, s.39 — Section 39 prohibits all controllers and processors established in the Bailiwick from processing personal data unless registered with the ODPA; failure to comply is a criminal offence.
- Probable https://www.dlapiperdataprotection.com/index.html?t=authority&c=GG — Office of the Data Protection Authority (ODPA) — The Bailiwick of Guernsey's data protection regulator, delegated day-to-day regulatory functions by the Data Protection Authority under the Data Protection (Bailiwick of Guernsey) Law, 2017.
- Confirmed https://www.odpa.gg/ — ODPA is the independent supervisory authority under the Data Protection (Bailiwick of Guernsey) Law, 2017.
- Probable Bailiwick Express — Data-protection registration and fee obligations were extended to require Alderney organisations to register with the ODPA from 1 January 2021. observed
- Confirmed ODPA guidance - 'Established in the Bailiwick' — Data Protection (Bailiwick of Guernsey) Law, 2017, s.111 — An entity is 'established in the Bailiwick', and thus caught by the Law, if it is a Guernsey/Alderney/Sark person, maintains an office/branch/agency or regular practice there, causes processing equipment there to be used other than for transit, or engages in effective and real processing through stable arrangements there. observed