LG Electronics Letter to ICO

This document relates to my LG Electronics Blog

To whom it may concern

I am writing to raise a regulatory concern regarding the data protection practices of LG Electronics U.K. Ltd, which I believe warrant the Information Commissioner’s Office’s attention due to their wider implications for consent and control in connected consumer devices.

In summary, LG conditions continued access to core product functionality, including third-party and locally operating applications, on acceptance of broad and evolving terms and conditions. Refusal results in the loss of previously purchased functionality. It was my own personal case in April 2025 that highlighted this matter when terms were enforced while displayed in a foreign language despite the device being configured for English, making informed consent impossible.

LG retains exclusive post-sale control over the device’s software and offers no meaningful alternative for users who do not consent. This creates a situation in which consent is effectively coerced rather than freely given, including where the underlying processing is not strictly necessary for the function being used.

I am also concerned by LG’s handling of the matter once challenged. Despite failing to submit a defence in the Small Claims proceedings and the claim being decided against them by default, LG has continued to insist that their patterns and practices are acceptable. This raises concern that procedural non-engagement may be being used to frustrate scrutiny, avoid transparency, and prevent examination of the underlying practices, rather than to resolve the substantive issues raised.

Taken together, these issues appear reflective of a wider industry pattern in “smart” consumer devices, where manufacturers leverage post-sale software control and ecosystem lock-in to impose new data processing conditions long after purchase, with refusal resulting in functional degradation.

I have attached a Small Claims Court submission relating to my LG television. This is provided not as a request for individual redress, but as supporting evidence of practices that raise serious and potentially systemic issues under UK data protection and consumer rights laws.

This situation warrants regulatory intervention to address how “always-on” or connected devices are sold and controlled post-sale.

  • Manufacturers should be required to provide clear pre-sale disclosure of which features are mutable/immutable, and which depend on online services.
  • Core functionality and product longevity should not be undermined by unilateral software changes.
  • Where services are withdrawn, suspended, or a manufacturer ceases trading, guarantees should exist to ensure that operating software, apps and features continue to function and that consumers have practical alternative means to maintain and use their devices.
  • Privacy, data collection, etc. notices should be provided pre-sale
  • Updates and changes should be optional with granular controls around what is updated, terms and privacy.

Thank you for your attention to this matter.

Kind regards

Dan Bayley