An introduction to the Data (Use and Access) Act 2025

The Data (Use and Access) Act 2025 will come into effect from 1 June this year. Our team introduces the act, looking into how it could impact your business.

For a more detailed overview of the Data Act, please read our recent article here.

The Data (Use and Access) Act 2025 (‘DUAA’) represents a significant development in the UK’s data protection framework. Among the reforms it introduces is a new requirement for all organisations to implement an internal data protection complaints procedure, designed to ensure that individuals can raise concerns directly with organisations before escalating matters to the Information Commissioner’s Office (ICO).

While the DUAA does not provide a specific format for the complaints process, it does establish minimum standards that organisations must meet. In particular, the internal procedure must:

• provide a clearly publicised and accessible complaints procedure
• acknowledge receipt of a complaint within 30 days
• investigate and handle complaints without undue delay, keeping the complainant informed throughout
• communicate the outcome clearly once the complaint has been concluded.

The ICO has confirmed that organisations must accept complaints via any channel, even where the individual does not use a designated complaints form or explicitly refer to data protection legislation.

What should organisations do?

This requirement applies to all organisations, regardless of size or industry. Existing complaints procedures should therefore be reviewed and updated to ensure they adequately cover data protection issues, or new procedures introduced where none currently exist.

Training will also be key. Staff must be able to recognise data protection complaints, understand how they differ from general grievances, and know how to escalate and handle them appropriately in line with the new statutory framework.

If you have any queries about the upcoming changes and require guidance, please get in touch with our team of experts.

Our Legal 500-rated employment law & business immigration team are experts in guiding businesses of all sizes and backgrounds through a range of issues that may arise.