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ARTICLE · 18 MAY 2026

A Quick Guide To New Data Protection Complaints Procedures For Pension Schemes

Shepherd and Wedderburn
Shepherd and Wedderburn
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The Data (Use and Access) Act 2025 mandates that pension scheme trustees establish a data protection complaints procedure by 19 June 2025.

United KingdomPrivacy
Sarah Holmes
Sarah Holmes
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The Data (Use and Access) Act 2025 introduces a new requirement for data controllers to implement a data protection complaints procedure – and the deadline to do so is 19 June this year.

For trustees, this is primarily about ensuring that members have a clear route to raise concerns about how their personal data is handled, and that those concerns are dealt with appropriately and promptly.

This quick guide sets out the key actions trustees should take now to comply with the new requirements, taking into account guidance from the Information Commissioner’s Office (ICO) and the Pensions Administration Standards Association (PASA).

What trustees need to do

1. Put in place a complaints process for data protection issues

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