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ARTICLE · 25 FEBRUARY 2026

Preparing For The Data (Use And Access) Act 2025: Upcoming Complaints Procedure Requirement

Mayer Brown
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The Data (Use and Access) Act 2025 ("DUAA") represents a significant reform to the UK's data protection framework. Most of the remaining data protection provisions came into force on 5 February 2026...

United KingdomPrivacy
Oliver Yaros
Oliver Yaros
Ellen Hepworth
Ellen Hepworth
Alasdair Maher
Alasdair Maher
Rebecca Keay
Rebecca Keay
Shannon Balnaves (trainee solicitor)
Shannon Balnaves (trainee solicitor)
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The Data (Use and Access) Act 2025 (“DUAA”) represents a significant reform to the UK's data protection framework. Most of the remaining data protection provisions came into force on 5 February 2026, bringing major changes to how organisations handle personal data.

With the main provisions now in force and the requirement for organisations to implement a formal procedure for handling and addressing complaints about the use of personal data approaching on 19 June 2026, businesses have a window of opportunity to review their data protection practices, update policies and procedures, and prepare for the new complaints-handling obligations.

The Information Commissioner's Office (“ICO”) has signalled a measured approach to enforcement during this transition period, particularly for areas where guidance is not yet finalised. However, compliance with the DUAA changes should be treated as an ongoing priority throughout 2026.

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