UK GDPR vs Data Act 2025: What’s Changed and How Enterprises Should Respond

What Happened

The UK Data Use and Access Act 2025 (DUAA) is the country’s largest data law reform since GDPR, aimed at empowering enterprises to innovate while retaining robust privacy standards. DUAA introduced targeted amendments that touch nearly every aspect of personal and non-personal data management, making compliance more streamlined and business-friendly for large organizations, especially those with cross-border interests.​

Detailed Changes

International Data Transfers: Enterprises can transfer data to countries with protections “not materially lower” than those in the UK, a move away from the more restrictive “essentially equivalent” EU approach, this expands options for global data flows, smoother partnerships, and more flexible outsourcing.​

Automated Decision-Making (ADM): Businesses have more freedom to use AI or algorithms for significant decisions, with requirements for transparency, human intervention, and mechanisms for individuals to challenge such decisions, crucial for financial, HR, and service industries.​

DSAR Handling: Companies must only make “reasonable and proportionate” efforts to respond to Data Subject Access Requests, and can pause the response timeline if clarification or ID verification is needed, reducing costly searches and administrative backlog.​

Recognized Legitimate Interests: DUAA lists specific interests (like crime prevention, safeguarding, direct marketing, intra-group data sharing) where enterprises gain automatic lawful processing powers without full balancing tests, easing compliance for internal and external operations.​

Cookie and Tracking Rules: Consent for nonintrusive cookies (analytics, error logging) is now optional, simplifying website operations and user experience management for large digital platforms.​

Scientific Research: Broader consent is allowed for research, including commercial activities and health innovation, with safeguards for privacy, enabling universities, pharma, and startups to operate with more clarity.​

Children's Data: New expectations for services accessed by children, requiring robust design for safety and data protection, directly impacting gaming, social media, and educational technology sectors.​

Complaint Mechanism: Businesses must now offer structured, timely complaint mechanisms to address data subject concerns before escalation to regulators, driving greater operational accountability and faster dispute resolution.​

Regulatory Restructuring: The Information Commissioner’s Office (ICO) will transition oversight powers to a new Commission, introducing advanced digital review processes and guidance expected into 2026.​

“The future of compliance is automation and agility. Static frameworks won’t keep pace with regulators or the market.”​

How It Happened

As the DUAA rolled out, many enterprises faced confusion navigating the divergence from EU standards and interpreting new procedures for international transfers, complaints handling, and automated decisions. The government’s intention was clear: “balancing innovation with robust protections”. However, staged implementation (over 2–12 months) and evolving ICO guidance required ongoing transformation of compliance frameworks. Executives found themselves balancing minimised administrative burdens with renewed direct accountability for privacy outcomes.​

How It Could Have Been Prevented

Enterprises caught off guard were mainly those slow to track regulatory signals and update compliance frameworks. Proactive companies already monitored legislative developments and engaged experts to stress-test their data practices for regulatory convergence and divergence.

“The best defence against regulatory change is agility, in workflows, systems, and attitudes.”​

How Sequenxa Can Solve the Problem

Sequenxa’s identity verification and compliance automation platform help enterprises adapt in real time to evolving legislative landscapes. With advanced workflow tools, dynamic compliance mapping, and future-proof data governance modules, Sequenxa ensures executives never miss a regulatory update and can respond with agile, informed strategies tailored to both UK and EU needs. As enterprise leaders look to avoid fines, loss of reputation, and operational disruption, Sequenxa offers compliance at enterprise speed, where innovation meets regulation.