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ARTICLE · 20 OCTOBER 2025

Risk Radar | September 2025

Foot Anstey
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Foot Anstey

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On 19 June 2025, the Data (Use and Access) Act 2025 (DUA) received Royal Assent, which has begun an overhaul of the UK's data governance framework.

United KingdomConsumer Protection
Nathan Peacey
Nathan Peacey
Tamzin Robson
Tamzin Robson

Data protection updates

Overhaul of the UK's data governance framework begins as the Data Use and Access Bill receives Royal Assent

On 19 June 2025, the Data (Use and Access) Act 2025 (DUA) received Royal Assent, which has begun an overhaul of the UK's data governance framework. Notably, the DUA will increase the maximum fines issuable under the Privacy and Electronic Communications Regulations to bring them in line with UK GDPR powers (up to £17.5 million or 4% of global turnover). See more information about the changes in our article here.

ICO consultation on draft "recognised legitimate interest" guidance

Organisations will be able to rely on the new lawful basis of "recognised legitimate interest" (which will be added by the DUA) for processing activities that are necessary to prevent crime. Organisations should review the relevant draft guidance on the new lawful basis here and respond to the consultation here with any comments.

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