DataIQ’s stance is clear: this legislation is more than an administrative shift but is an opportunity for success if data leaders are willing to engage strategically, not reactively.
Revisit and Rationalise Consent and Legitimate Interest Strategies
The Act’s clarification around Recognised Legitimate Interests offers organisations a clearer route to data processing without always defaulting to consent. But this is not a carte blanche environment. This evolution is a chance to revisit how consent is used (not abandon it) and pressure-test where legitimate interest can be applied more confidently, with accountability built in.
Actions for leaders:
- Audit existing lawful bases for personal data use.
- Reframe risk appetite for borderline cases using the new clarity.
- Re-engage legal and compliance teams not just to interpret the rules, but to co-design policy with product, AI and customer leaders.
Pressure-Test Governance and Culture, Not Just Processes
Legislation can adjust frameworks, but cultural dynamics shift much more slowly. The Act implies a more innovation-aware Information Commissioner’s Office (ICO), but enforcement will not be defined top-down alone. Organisations that set the pace through robust internal governance, codes of conduct, and evidence of meaningful oversight will be the ones to ultimately shape the tone.
DataIQ clients are the testbed for such cultural translation: where peer-led examples inform both risk mitigation and performance strategies.
Actions for leaders:
- Refresh data governance models: who owns what, where decision-making authority sits, and how trade-offs are made.
- Participate in regulatory consultations and industry codes to proactively influence how new powers are applied in practice.
- Elevate human-in-the-loop processes around AI decisions for compliance and better organisational judgement.
Ready Teams for Smart Data Schemes and Data Portability
The Act’s provisions on smart data extend the open banking model into other regulated sectors, meaning secure, customer-authorised data sharing is coming to telcos, utilities, insurance, and beyond.
This highlights a data architecture problem alongside a business model shift that assumes customers can (and will) demand their data be made portable: easily, securely, and interoperably.
Actions for leaders:
- Map out the maturity of APIs and data sharing protocols before regulators or competitors force the issue.
- Invest in technical infrastructure, but also in product and customer teams’ understanding of data portability as a differentiator.
- Collaborate with peers through DataIQ to understand how others are approaching sector-specific implementation.
Accountability in Automated Decision-Making
Meaningful human oversight is a design principle. As the Act clarifies expectations around Automated Decision-Making (ADM) , data and AI leaders must move beyond vague disclaimers into auditable, transparent governance. The standard is now: “Could you demonstrate how a competent individual shaped this decision?”
Actions for leaders:
- Catalogue where ADM is already in use, and how oversight is applied.
- Embed governance into the design of models, not just the back end of review processes.
- Draw on cross-functional insight (legal, ethical, operational) to define what meaningful intervention should look like.
Embed Children’s Data as a High-Protection Category
Organisations whose services reach under-18s must now handle that data under heightened expectations. DataIQ clients have consistently surfaced how reputational risk on children’s data far outweighs legal exposure alone.
Actions for leaders:
- Apply the same design rigour to children’s data as you would to safety-critical engineering.
- Build red teams or ethical reviews into product development cycles that touch young users.
- Use DataIQ events and insight series to understand lived experience across sectors, especially where ambiguities remain.
Track International Data Transfer Implications
The Act’s provisions around law enforcement and cloud providers may invite scrutiny from the EU, potentially affecting the UK’s adequacy decision. This is a live risk area and one where legal interpretation will not be uniform across borders meaning diligence is needed.
Actions for leaders:
- Reassess international data transfer agreements and fallback mechanisms.
- Monitor ICO and European responses in tandem.
- Attend DataIQ meetups and roundtables as a forum to assess collective exposure and mitigation options.
Drive Change Through Engagement, Not Wait-and-See
Regulation alone will not build trust or competitive advantage; it must be coupled with design. DataIQ’s view is that regulatory reform should catalyse purposeful, transparent innovation. But the sector needs leaders willing to raise their voice for compliance and to shape the new norms.
Actions for leaders:
- Participate in collaborative forums to absorb guidance and help set examples.
- Treat regulatory interpretation as a strategic capability, not an overhead.
- Lean on the DataIQ community as a sounding board, a testing ground, and a source of peer-driven insight.
Rules Change, Not the Fundamentals
The UK Data (Use and Access) Act 2025 is a moment of reorientation. But the fundamentals of responsible data use as a driver of innovation still applies.
DataIQ’s role is to serve as the help button for data and AI leaders, curating real-world examples, decoding complexity, and equipping our clients with the insights they need to move forward with both confidence and caution.
For senior data and AI professionals: this legislation rewards clarity, design, and trust. It is about shaping what comes next, not just keeping up.
