UK data protection complaints for commercial organisations: ICO‑aligned process, distinguishing DSARs, and DUAA 2025 complaint‑handling obligations effective 19 June 2026

Published by a LexisNexis Risk & Compliance expert

Practice notes

This Practice Note is aimed at commercial organisations across the UK. It sets out practical direction on responding to data protection complaints and points to supporting tools designed to mirror the ICO’s suggested complaints-handling approach. At present, organisations are not legally required to manage data protection complaints; the UK GDPR grants the right to complain to the Information Commissioner’s Office (ICO). From 19 June 2026, however, the Data (Use and Access) Act 2025 (DUAA 2025) will introduce mandatory complaint-handling duties for commercial organisations—see section: Impact of Data (Use and Access) Act 2025. Until then, guidance and tools issued by the ICO indicate the ICO will generally not take forward a data protection complaint unless it has first been raised with the organisation concerned...

The right to complain

Data subjects may lodge a complaint with the ICO where they believe their personal data has been processed in a manner that breaches the UK GDPR. They can also complain to the ICO through a not-for-profit body, organisation or association. The ICO is required to investigate complaints to the extent appropriate and inform the complainant of the...

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Web page updated on 22/05/2026

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