UK Report September 2026

UK Report - Issue 147

02 September 2026

UK Report September 2026

Overview

Contents

COMMENTS

• Six pointers to 2026 as a Time of Transition
• ICO’s draft strategy lacks detail

LEAD STORIES

• UK should apply a mix of adequacy decisions and alternative data transfer tools
  John Kavanagh of TikTok advocates for increased flexibility in adequacy and validated data security compliance measures as a transfer tool.
• Friend and Foe: AI is taking over Data Subject Access Requests
  AI is being used to both generate and respond to Data Subject Access Requests. Tom Cooper reports on how a deft human touch remains vital.

NEWS

• Do the fundamental things still apply in UK data law?

ANALYSIS

• Have we missed the Secretary of State in the room?
• Monitoring technologies in UK workplaces: What does the future hold?
• Can consent mechanisms stretch to AI agents?

MANAGEMENT

• Managing your privacy supply chain: Perils and pitfalls

NEWS IN BRIEF

• ICO issues skeleton draft strategy
  
• IC’s new non-executive members appointed
  
• DSIT (now DCMS) consults on data transfers, AI and re-use of public sector data
  
• Upper Tribunal dismisses TikTok appeal
  
• Chair of Information Commission being recruited
  
• House of Lords seeks evidence on Online Safety Act enforcement
  
• Afghan data breach: Firmer accountability needed
  
• Use of VPNs rises sharply with age