Mandatory Changes to UK GDPR and Your Privacy Policies
Following the rollout of the Data (Use and Access) Act 2025, significant changes to the UK GDPR are now legally in force from 19 June 2026.
The UK data protection landscape has officially transformed. Following the rollout of the Data (Use and Access) Act 2025, significant changes to the UK GDPR are now legally in force from 19 June 2026.
The biggest shift involves a new statutory right for individuals. This includes your employees, customers, and clients – to log data complaints directly with your organisation. If you have not yet formalised your internal data complaint procedures, your business is currently exposed to regulatory non-compliance.
Below is everything you need to know to ensure your business operations remain fully compliant.
The Key Changes
Mandatory Internal Complaints Process: Individuals can no longer bypass your business to complain directly to the Information Commissioner’s Office (ICO) under Article 77. They must now raise data protection complaints with you first. You are legally required to provide a clear, accessible route for them to do so.
Strict 30-Day Response Windows: Upon receiving an internal data complaint, your business has a maximum of 30 days to formally acknowledge it. You must then investigate the matter and provide updates “without undue delay”.
New “Recognised Legitimate Interests”: The legal grounds for processing data have been updated. A new lawful processing basis has been introduced to cover specific public interest tasks, emergency responses, and national security data sharing. Removing the requirement for standard balancing tests in these scenarios.
Updated International Data Transfer Test: Under the new Article 44A framework, rules regarding the transfer of personal data outside of the UK have been modified. You must ensure your international data flows satisfy the newly defined “Data Protection Test”.
What This Means for Your HR Operations
Data privacy is deeply tied to HR management. Your employees (and ex-employees) frequently exercise their data rights. They are now legally entitled to a formal, structured response if they believe their personal information or payroll data has been mishandled.
Relying on standard, unmonitored HR email inboxes for data privacy disputes will no longer suffice. Failing to establish a transparent internal tracking and resolution workflow will place your organisation in immediate breach.
Checklist: How to Ensure Compliance
To fully align with the current UK data laws, we recommend auditing the following areas immediately:
- Rewrite Your Privacy Notices: Update your staff handbooks, recruitment privacy notices, and external website privacy policies to explicitly outline the new internal complaints mechanism.
- Establish a Data Complaint Channel: Set up a dedicated, accessible channel (such as a specific web form or monitored inbox) for data protection grievances.
- Train Your Internal Teams: Educate your management teams on how to identify a data complaint and log it within the statutory 30-day window.
- Audit International Contracts: If you utilise overseas HR software, payroll vendors, or cloud storage platforms, verify that their contracts comply with the new international transfer test.
How We Can Support You
We are here to take the compliance burden off your shoulders and are in the process of updating our clients’ employee handbooks.
If we don’t currently provide your HR documents or employee handbooks and you would like us to review your policy, then please contact us