UK Data Use and Access Act (DUAA)

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If you’ve been keeping an eye on the UK’s data landscape, you’ve probably heard about the Data (Use and Access) Act 2025—DUAA for short. This piece of legislation, which got the royal nod back on June 19, 2025, is shaking things up in how businesses, public bodies, and even law enforcement handle personal data. It’s not a complete overhaul, but it does introduce some smart adjustments aimed at boosting innovation while trying to keep privacy protections intact. As someone who’s dug into the details from official sources like the ICO and government guidance, I’ll break it down here in a way that’s easy to follow.

What’s the Big Picture Behind the DUAA?

The DUAA isn’t coming out of nowhere. It’s built on the UK’s existing framework—the UK GDPR, the Data Protection Act 2018, and those pesky Privacy and Electronic Communications Regulations (PECR). The goal? Make things simpler for organizations to use data responsibly, encourage economic growth, and support things like crime prevention without drowning everyone in red tape. Implementation is rolling out in phases, which started back in August 2025, with full effects by mid-2026.

Critics might say it’s a bit of a balancing act: easing rules to spark innovation but risking weaker safeguards for individuals. From what I’ve seen, though, the changes lean more toward flexibility for companies, especially in tech and research sectors. The government reckons this will help the UK stay competitive post-Brexit, and the ICO is on board, promising updated guidance to smooth the transition.

DUAA UK Privacy

The Data (Use and Access) Act 2025 Changes for 2026

Let’s get into the nitty-gritty. The Act touches on several core areas of data protection. Here’s a rundown of the main ones, based on the ICO’s breakdowns and government summaries.

Automated Decision-Making Gets a Boost

One of the flashier updates is around automated decision-making (ADM)—think AI systems that make big calls on things like loan approvals or job screenings without human input. Previously, this was pretty restricted under UK GDPR, but now organizations have more leeway to use ADM as long as they build in safeguards. That means telling people about the decision, letting them challenge it, and offering human review. For law enforcement, there’s even an exemption in sensitive cases like national security, but they have to loop in a human ASAP afterward.

This could be huge for efficiency in sectors like finance or HR, but it raises eyebrows about bias in algorithms. If you’re running a business, now’s the time to audit your AI tools and ensure those safeguards are rock-solid.

Legitimate Interests: New “Recognized” Grounds

“Legitimate interests” as a basis for processing data just got an upgrade. The DUAA adds “recognized legitimate interests” for specific public-good activities, like preventing crime, safeguarding vulnerable people, or handling emergencies. The big win? No need for that tedious balancing test—you can just go ahead if it fits the bill.

Public authorities should stick to their “public task” basis for now, per ICO advice, but for private firms, this opens doors for more proactive data use. Imagine retailers sharing info to spot fraud without jumping through hoops—it’s practical, but expect the ICO to watch closely for overreach.

Scientific Research: Broader and More Flexible

Research folks, rejoice. The Act clarifies that “scientific research” includes commercial stuff, not just academic pursuits. You can now get broad consent for entire research areas rather than specific projects, and if re-using data without a fresh privacy notice is too tricky, you can skip it—as long as you post it online and protect rights.

This is a nod to innovation in biotech or AI, where data is gold. But it’s not a free-for-all; safeguards are mandatory, and the ICO’s upcoming guidance will likely spell out the dos and don’ts.

Complaints Handling: A New Must-Do

By June 2026, every organization has to have a proper process for data protection complaints. That includes easy electronic forms, acknowledging gripes within 30 days, and responding promptly. No more brushing off unhappy customers—the ICO’s draft guidance emphasizes clear procedures and record-keeping.

This one’s straightforward but important. Small businesses might find it a hassle, but it’s about building trust. Plus, it aligns with broader accountability trends.

Cookies and Storage Tech: Less Consent Drama

Tired of cookie banners? The DUAA lets organizations use storage tech (like cookies) without consent in low-risk scenarios, such as stats collection or audience measurement. It’s a small change, but it could clean up websites and make marketing smoother for charities with a “soft opt-in” for emails.

Other Notable Tweaks

  • Subject Access Requests (SARs): Only “reasonable and proportionate” searches needed, and you can “stop the clock” while waiting for more info from the requester.
  • Children’s Data: Online services must factor in kids’ needs from the design stage, tying into the ICO’s Age Appropriate Design Code.
  • International Transfers: Rules simplified for smoother global data flows.
  • Law Enforcement and Intel: Mirrored changes for consistency, with some exemptions for security.

Implications for Businesses and Public Bodies

For organizations, this Act is mostly good news—more flexibility means less bureaucracy, potentially cutting costs and speeding up decisions. Tech startups and researchers get a leg up, but you’ll need to update policies, especially on ADM and complaints. The ICO is rolling out consultations (closing in October 2025) on key bits like legitimate interests, so chime in if you can.

Public authorities and law enforcement get efficiency boosts, like easier data sharing for public tasks. But remember, the ICO’s getting new powers too, so compliance isn’t optional.

What About Individuals? Your Rights in the Mix

On the flip side, individuals aren’t left out. You get better transparency on ADM, rights to challenge decisions, and easier ways to complain. Kids’ online safety gets a boost, and overall, the Act claims to maintain high standards. That said, with more data flowing freely for “legitimate” reasons, privacy advocates might worry about creep—will companies push boundaries?

Innovation vs. Privacy—Who Wins?

The DUAA strikes me as a pragmatic update, tilting toward business needs without gutting protections. It’s not revolutionary, but in a world where data drives everything, these tweaks could fuel UK growth. Keep an eye on the ICO’s evolving guidance—they’re the ones who’ll enforce this.

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