The Data (Use and Access) Act (DUAA), passed in summer 2025, brought with it some novelties such as the smart data provisions, digital ID verification, and changes to the composition of the ICO. While some of these changes are still to come, the data protection provisions are now all in place.

A panel chaired by Greg Palmer, Partner at Linklaters, discussed the reform from different angles. Elisabeth Stafford, Head, Data Protection Act Reform, Department for Science, Innovation and Technology (DSIT), explained that the government is now occupied with implementing the Act properly. Some provisions needed transitional arrangements (note DSIT has since been discontinued, see below­). Actions that started before all the provisions commenced – e.g. DSARs that were received before the new Act was in force – needed careful attention.