On 11 June 2025, UK Parliament completed the final round of “ping‑pong” over the Data (Use and Access) Bill in the House of Lords, paving the way for Royal Assent and its conversion into the Data (Use and Access) Act 2025 This is a major milestone in updating the UK’s data protection landscape post‑Brexit—and it signals that smart, responsible data use is now firmly on the national agenda.

What You Should Know

The Act introduces several important refinements:

  • A staggered roll‑out of updated UK GDPR provisions, including relaxed rules around cookies, Data Subject Access Requests (DSAR), automated decision‑making, and strengthened provisions for scientific research

  • A formal category of “recognised legitimate interests”, clarifying when data can be used without a full Legitimate Interests Assessment

  • A framework to support smart data sharing schemes, such as expanding open banking into Open Finance—supporting public innovation and estimated to boost GDP substantially 

Why Data Hygiene Is Mission‑Critical

Good data hygiene is no longer optional—it’s foundational. As these reforms take hold, businesses must be able to show:

  • That data used in automated decision-making is accurate, auditable, and bias-free.

  • That DSARs are supported by search systems capable of delivering across legitimate interest grounds.

  • That customer data is kept clean and up to date to support future regulation—and to power smart data-sharing schemes securely and compliantly.

Next Steps for You

We expect the Act to become law before the summer recess, with provisions rolling out over the next 12 months.

In preparation, it is recommended by the ICO that the focus should be on:

  1. Auditing your data processes, especially those used in automations;

  2. Review consent frameworks and privacy notices to align with new guidance;

  3. Ensure data accuracy and governance to meet future DSAR and legitimate interest demands.

As these legislative changes come into force, we can help ensure that your data is in the best possible shape. If you would like to find out more get in touch!