Policy To Practice: Lessons From The Uk's New Data Protection Complaints Framework

Executive Summary

The United Kingdom's Data (Use and Access) Act 2025 (DUAA) introduces one of the most significant operational reforms to the UK's data protection framework since Brexit. Among its key reforms is a statutory requirement for organisations that process personal data to establish and maintain a documented data protection complaints procedure by 19 June 2026.

Although the requirement applies directly to organisations subject to UK data protection law, its significance extends beyond the UK. It reflects a broader regulatory trend towards demonstrable accountability, with regulators increasingly expecting organisations to show not only that they have appropriate policies in place, but also that they have effective processes for handling complaints and protecting individuals' rights in practice. For Nigerian organisations, particularly those involved in cross-border processing, financial services, technology, outsourcing or multinational operations, the reforms offer a