Eight years at the data protection function of 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.
A specialist DPO consultancy, not a generalist firm. Data protection is all I do — it is not a side offering within a broader IT or legal practice.
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 the latest 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 business this quarter. Someone who has handled enough breaches to know which ones genuinely require notification and which are noise.
That is what I am building with Varnham Consulting. 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.
Data protection is unfortunately a profession where credentials matter more than they should. These are the ones I hold and what they actually mean.
The IAPP's flagship certification covering the legal and regulatory framework of European data protection — UK GDPR, the Data Protection Act 2018, and the regulatory bodies that enforce them. The qualification regulators expect a senior practitioner 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.
High-volume DSAR handling, FCA and ICO reporting, international transfer assessments, breach response, three-lines-of-defence governance. The depth of experience that does not exist in most consultancies of this size.
Registered as a data controller in my own right. The minimum bar for any data protection adviser; less common than it should be in this market.
Trusteeships and governorships across charitable and educational organisations. Direct experience of how data protection obligations manifest at board level — what trustees ask, what auditors look for, what survives a contested meeting.
Carried at a level appropriate to the engagements undertaken, with AI-delivery carve-in. Confirmation available on request before engagement commences.
You work with me directly, not a rotating pool of consultants. I learn your business, your data flows, your systems, and your risk profile over time. The person who writes your services agreement is the person who attends your governance meetings.
Everything I deliver 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 backbone of every assessment, every report, every plan.
I have implemented data protection in large, complex organisations where pragmatism matters. My advice works in the real world — I know where the real risks lie and where pragmatic, proportionate measures are sufficient.
Structured governance, ongoing monitoring, regulatory change tracking, and a compliance evidence base that builds over time. The aim is to prevent incidents rather than respond to them well.
Your 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, every deliverable is filed, version-controlled, and stored in a structured compliance library. If the ICO comes knocking, the evidence base is already in place — not constructed under deadline.
An SME engaging a DPO with banking-sector experience gets two things that most SME-focused consultancies cannot offer.
First, exposure to the hardest compliance problems. If you have managed international data transfers across a global banking group, advising a technology company on a single cloud-hosting arrangement is a matter of applying familiar principles at a simpler scale.
Second, a compliance standard calibrated to regulatory expectations. I know what the ICO looks for because I have been through the process — not theoretically, but in practice. This does not mean I over-engineer compliance for SMEs. It means I know where the real risks lie and where pragmatic, proportionate measures are sufficient.
I will listen, answer your questions, and advise on the best next step. If we are not a fit, I will say so — and where appropriate, point you to someone who is.
Start with the intake form. A short intake is the only way in — name, email, phone, and the nature of your enquiry. After you submit, I will respond personally within one working day.
The form takes under two minutes. After you submit, I will respond within one working day with the right next step for your situation.