Laws, Standards & Compliance

UK GDPR and the Data (Use and Access) Act

Also known as: UK GDPR, Data (Use and Access) Act 2025, DUAA, UK data protection law, Data Protection Act 2018

UK GDPR is the version of the EU's General Data Protection Regulation that the United Kingdom kept in domestic law after Brexit, alongside the Data Protection Act 2018.

The Data (Use and Access) Act 2025 then reformed it, easing rules on legitimate interests, automated decisions, and cookies. While the reforms gave the UK more flexibility, they were carefully limited, because straying too far from EU rules could cost the UK its EU adequacy status.

UK GDPR and the Data (Use and Access) Act, explained at three levels

At home

Think of UK GDPR as a photocopy of the EU's privacy rulebook that the UK kept after Brexit, then started editing in the margins. Your rights are almost the same as in the EU: you can see, correct, and delete your personal data and object to some uses. The 2025 Data (Use and Access) Act made targeted edits, mostly easing rules for businesses rather than removing your rights.

At work

UK GDPR is the UK's domestic version of the EU GDPR, read alongside the Data Protection Act 2018. The Data (Use and Access) Act 2025 amended both, changing rules on legitimate interests, automated decisions, research, cookies, and complaints handling. Businesses care because UK and EU rules are now similar but not identical, so a company serving both markets must track the differences and may need representatives in each.

Real-world examples

At home

Thomas, a Londoner, noticed that some websites stopped asking for consent to basic analytics cookies after the UK reforms. He could still opt out in their settings, but the banners became less frequent for low-risk tracking.

At work

Fatima runs privacy at a Canadian software company with clients in London and Paris. After the Data (Use and Access) Act passed, she updated the UK section of the company's privacy notice and cookie settings, but kept the core program aligned with EU GDPR, since the EU remained the stricter regime.

How it compares

featureUK GDPR (as reformed)EU GDPR
Legal basisIncludes recognised legitimate interests without balancing testLegitimate interests always require balancing
Automated decisionsBroadly permitted with safeguardsRestricted, with limited exceptions
Low-risk cookiesSome exempt from consentConsent generally required under ePrivacy rules
RegulatorInformation Commission (formerly ICO)National authorities plus the EDPB
Transfers outUK adequacy regulations, IDTA, addendumAdequacy decisions, SCCs, BCRs

UK GDPR remains close to EU GDPR, with targeted relaxations that the EU has so far accepted.

For analysts

If you operate in both the UK and the EU, I'd resist the temptation to run separate programs. Build to EU GDPR and document UK exceptions. The differences are real but small, and two programs double the maintenance.

History & origin

When the Brexit transition period ended on December 31, 2020, GDPR was copied into UK law as 'UK GDPR,' effective January 1, 2021. The European Commission granted the UK an adequacy decision in June 2021, allowing EU data to keep flowing freely, with a sunset clause requiring review. After assessing the 2025 reforms, the Commission renewed the UK's adequacy in December 2025, until December 2031. The UK government tried several reform bills, including the Data Protection and Digital Information Bill, which died when the 2024 general election was called. The Data (Use and Access) Act received Royal Assent on June 19, 2025, with provisions commenced in stages. It also restructures the Information Commissioner's Office into an Information Commission. In my opinion, the UK's reforms show the gravitational pull of EU rules. Even after leaving, the UK couldn't move far without risking a major trade cost.