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UK Data (Use and Access) Act 2025: UK GDPR and PECR reforms - recognised legitimate interests, transfers, automated decision-making, children's safeguards, cookies, higher PECR fines and mandatory complaints procedures

Published on: 29 September 2025

Published by a LexisNexis Corporate Crime expert
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The Data (Use and Access) Act 2025 (DUAA 2025)

The Data (Use and Access) Act 2025 (DUAA 2025) secured Royal Assent on 19 June 2025, with DSIT (the Department for Science, Innovation and Technology) billing it as a new law that will ‘make life easier’. The Information Commissioner’s Office (ICO) similarly notes it ‘offer[s] you an opportunity to do things differently’.

What key changes are introduced by the DUAA 2025?

Many provisions in DUAA 2025 are to be brought into effect by secondary legislation made by the Secretary of State. Commencement No 1, described as stage one, has already appeared and is unrelated to data protection. Stage three, scheduled six months after Royal Assent—ie, 19 December—will trigger the commencement of the principal amendments to data protection legislation in DUAA 2025, Part 5. An immediate shift took place on the day of Royal Assent: searches carried out when responding to data subject requests must, by legislation, be ‘reasonable and proportionate’, a standard that the ICO had already set out in its guidance. The ICO’s detailed summary of DUAA 2025 also underscores that several passages inserted into the Act have been drawn from recitals in the current UK GDPR...

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