The entire DP regulatory system is toothless
"insisting that cooperation, guidance, and "proportionate" responses achieve better long-term compliance than headline-grabbing penalties"
The expression "headline-grabbing penalties" clearly indicates that the ICO doesn't have a clue about what minimises data breaches. And whether .cooperation, guidance, and "proportionate" responses' deliver useful results depends entirely on the definition of those terms and their applicability to individual cases. (BTW it's revealing that the word proportionate is double quoted, as if it's not to be taken seriously.
Via submissions to several govt. consultations on data protection over the years I have repeatedly suggested that a more effective response would be in three phases: an enforced independent audit of the breach, a set of mandatory remediation actions and an independent post-implementation audit to confirm they were in place and working -- all at the breaching organisation's expense. This would be vastly more effective than fines, which to many organisations are just a cost of doing business (and against which they may even be insured).
So far my suggestion has apparently fallen on deaf ears and the ICO has increasingly ignored pretty much all but high profile data breaches that gain mainstream media attention, even where (in my direct professional experience) the implications of apparently minor infractions have had potentially far reaching consequences. This (underlined by the expression "headline-grabbing penalties") leads me to the (possibly uncharitable but inescapable) impression that the ICO might be at least as concerned about enhancing its public image as it is about fulfilling its ostensible role in protecting the public (a well recognised stage in organisational decline).
For reference: I am a 40-odd year veteran in information management with professional involvement in data protection since the 1984 Act
.