Data Governance Atlas UK edition

Track changes since 2025

13 amended provisions across 3 instruments, each shown before and after with the words that changed highlighted, the date it took effect, and, where held, the exact statutory wording now in force.

Data Protection Act 2018

Complaints to controllers s.164A In force from 2026-06-19
Before

No statutory duty on controllers to handle complaints. A complaint went straight to the regulator.

After

Controllers must make complaints easy to lodge, acknowledge them within 30 days and respond without undue delay. The regulator comes second.

Effect summary in the site's own words, not statutory text.

A data subject may make a complaint to the controller.
DPA 2018 s.164A(1). Exact wording, retrieved 2026-11-08. Contains public sector information licensed under the Open Government Licence v3.0.
The regulator Part 5 In force from 2026-09-30
Before

The Information Commissioner, a corporation sole.

After

The Information Commission, a body corporate led by a board, with the same role and powers.

Effect summary in the site's own words, not statutory text.

Investigatory powers Part 6 In force from 2026-02-05
Before

Information notices, assessment notices, enforcement notices and penalty notices.

After

Information notices, assessment notices, interview notices, a power to require a report, enforcement notices and penalty notices.

Effect summary in the site's own words, not statutory text.

Privacy and Electronic Communications (EC Directive) Regulations 2003

Breach notification deadline reg 5A(2) In force from 2025-08-20
Before

Notify the regulator of a personal data breach within 24 hours of detection.

After

Notify the regulator without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach.

Effect summary in the site's own words, not statutory text.

where feasible, not later than 72 hours after having become aware of it
PECR reg 5A(2). Exact wording, retrieved 2026-11-08. Contains public sector information licensed under the Open Government Licence v3.0.
Storage and access exceptions reg 6, Sch A1 In force from 2026-02-05
Before

Consent for any storage or access except for transmission or where strictly necessary for a requested service.

After

Consent for any storage or access except for transmission, where strictly necessary, for statistical purposes, for website appearance, or for emergency assistance, on conditions.

Effect summary in the site's own words, not statutory text.

Penalties Enforcement provisions In force from 2026-02-05
Before

Monetary penalties of up to £500,000.

After

Penalties of up to the higher of £17.5m or 4% of worldwide turnover, under the DPA 2018 enforcement toolkit.

Effect summary in the site's own words, not statutory text.

Soft opt-in reg 22 In force from 2026-02-05
Before

Soft opt-in for contact details obtained in a sale or negotiation for a sale only.

After

Soft opt-in for contact details obtained in a sale or negotiation for a sale, plus a charity soft opt-in for supporters, on conditions.

Effect summary in the site's own words, not statutory text.

UK GDPR

Recognised legitimate interests Art 6(1)(ea), Art 6(5), Annex 1 In force from 2026-02-05
Before

Six lawful bases. Legitimate interests always needs the balancing test against the interests and rights of the person.

After

Seven lawful bases. A recognised legitimate interest listed in Annex 1 needs no balancing test, only a condition in Annex 1.

Effect summary in the site's own words, not statutory text.

processing is necessary for the purposes of a recognised legitimate interest;
UK GDPR Art 6(1)(ea). Exact wording, retrieved 2026-11-08. Contains public sector information licensed under the Open Government Licence v3.0.
Time limits for responding Art 12 In force from 2026-02-05
Before

One month to respond, extendable by two months. Pausing the clock for identity or clarification rests on guidance.

After

One month to respond, extendable by two months. The clock stops by statute while the controller reasonably waits for identity or clarification.

Effect summary in the site's own words, not statutory text.

Reasonable and proportionate search Art 15(1A) In force from 2025-06-19
Before

Right of access to the personal data and the supplementary information, with no codified limit on the search.

After

Right of access limited to what the controller can provide based on a reasonable and proportionate search.

Effect summary in the site's own words, not statutory text.

Under paragraph 1, the data subject is only entitled to such confirmation, personal data and other information as the controller is able to provide based on a reasonable and proportionate search.
UK GDPR Art 15(1A), inserted by DUAA 2025 s.78. Exact wording, retrieved 2026-11-08. Contains public sector information licensed under the Open Government Licence v3.0.
Automated decision-making Art 22 replaced by Arts 22A to 22D In force from 2026-02-05
Before

A right not to be subject to a decision based solely on automated processing with legal or similarly significant effects, unless one of three exceptions applies.

After

Decisions based solely on automated processing with legal or similarly significant effects are permitted with safeguards, with tighter limits where special category data is used.

Effect summary in the site's own words, not statutory text.

there is no meaningful human involvement in the taking of the decision
UK GDPR Art 22A (meaning of a decision based solely on automated processing). Exact wording, retrieved 2026-11-08. Contains public sector information licensed under the Open Government Licence v3.0.
Children's higher protection matters Art 25 In force from 2026-02-05
Before

Data protection by design and by default, with no express reference to children.

After

Data protection by design and by default must take account of children's higher protection matters where a service is likely to be accessed by children.

Effect summary in the site's own words, not statutory text.

International transfers Chapter V In force from 2026-02-05
Before

Transfers assessed against the inherited EU standard of essentially equivalent protection.

After

Transfers assessed against the data protection test: protection not materially lower than in the UK.

Effect summary in the site's own words, not statutory text.