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UK Data (Use and Access) Act: What Changed from UK GDPR

What the UK Data (Use and Access) Act changes relative to UK GDPR — and how UK establishments should update programmes.

Published: September 2026 Compliance · Privacy 8–12 min read

The UK continues to evolve its post-Brexit data protection framework. The Data (Use and Access) Act adjusts aspects of the UK regime while UK GDPR and the Data Protection Act 2018 remain core references.

UK establishments and dual EU/UK operators should inventory what actually changed for their processing — not assume a full rewrite.

Programme advice: Diff your policies against official Explanatory Notes and ICO materials; keep EU GDPR obligations intact for EU processing.

How to read the change set

Focus on research/innovation provisions, digital verification themes, and any adjustments to complaint/enforcement mechanics that affect your operating procedures. Confirm details in primary text.

Dual EU/UK operators

Maintain separate records where rules diverge; avoid a lowest-common-denominator notice that misstates either regime.

Operational updates

How CyberSilo Helps

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Map evidence and operations with CyberSilo CSA and ThreatHawk.

Frequently Asked Questions

Did UK GDPR disappear?

No — the UK framework builds on UK GDPR/DPA 2018 with statutory updates.

Do we need a new lawful basis project?

Only if your processing relies on changed provisions — review with counsel.

ICO role?

Monitor ICO guidance for practical expectations.

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