The Data (Use and Access) Act 2025: Preparing for the new complaints regime

By Forbes Solicitors

22 Apr 2026

The Data (Use and Access) Act 2025.png.png

The Data (Use and Access) Act 2025 (DUAA) introduces an important obligation for organisations handling personal data.

From 19 June 2026, all organisations acting as data controllers are required to have in place an effective process to enable individuals to raise complaints about how their personal data is handled.

What does this mean in practice?

Organisations will be required to ensure that individuals can easily raise concerns, and that those concerns are properly acknowledged and addressed within appropriate timeframes.

Organisations with existing complaints procedures should not assume these will be sufficient. A thorough review of any existing policies will be necessary to ensure current processes meet the standards set by the DUAA.

Where no suitable procedures currently exists, organisations will need to create and implement a compliant procedure well in advance of the June 2026 deadline.

Documentation and transparency

While the DUAA does not expressly mandate a standalone written complaints policy, in practice organisations will be expected to document their procedures. This reflects the broader accountability principle under UK data protection law and will be important in demonstrating compliance.

Organisations should also consider:

updating privacy notices to clearly inform individuals of their right to complain and how to do so;
ensuring internal policies accurately reflect the complaints handling process; and
maintaining appropriate records of complaints received and how they have been managed.
Contracts with third parties

Where processing activities are outsourced to third party service providers, contractual arrangements with these sub processors should be reviewed to ensure they adequately address complaints handling. In particular, agreements should:

require processors to promptly notify the controller of any data protection complaint they receive; and
oblige processors to provide reasonable assistance in investigating and resolving complaints.
This is essential to ensure controllers remain able to meet their legal obligations, even where processing is carried out on their behalf.

Staff training and awareness

The effectiveness of any complaints process will depend on staff understanding their responsibilities. It is therefore imperative that organisations:

clearly identify who is responsible for handling data protection complaints;
ensure all staff can recognise a data protection complaint, even where it is not expressly labelled as such; and
provide clear internal guidance on escalation procedures.
Training on complaints handling should form part of wider data protection training programmes and be reviewed regularly.

Get in touch

With the implementation date approaching, organisations should begin preparing now.

Taking proactive steps will help minimise compliance risk and ensure complaints are handled efficiently, consistently, and in line with the new legal framework.

If you would like to discuss how these changes may affect your organisation, or require support in developing a compliant complaints procedure, please contact our data protection team.

Latest news

1

Bensons for Beds returns to Burnley with six-figure investment in new store PDA260717 12631

Bensons for Beds returns to Burnley with six-figure investment in new store

17 Jul 2026

2

FW Capital strengthens its portfolio team with a new appointment Simon Robb And Gary GuestUNP FW Capital 47974 Manchester005

FW Capital strengthens its portfolio team with a new appointment

17 Jul 2026

3

Freshfield appoints Megan Leeming to senior PR role Megan LeemingFreshfield Senior Manager

Freshfield appoints Megan Leeming to senior PR role

17 Jul 2026

4

Lancashire Business View launches issue 129 LBV Issue 129 Launch Event

Lancashire Business View launches issue 129

17 Jul 2026

5

Four council future for Lancashire Lancashire County Council County Hall

Four council future for Lancashire

16 Jul 2026

Blackburn College (July-Aug 26)
Background image for hub sign up block

LBV Hub

Leverage Lancashire Business View platforms

Post your news
Post your events
Post your offers
Build your network
Improve your SEO
Gain coverage in the magazine
Sign-up
Events
LBV130 September/October Magazine Networking Event
Jan/Feb Networking Event - Entrance
Networking
17 Sep 2026

LBV130 September/October Magazine Networking Event

The Beehive Blackburn, Shadsworth Business Park, BB1 2QS

08:30 - 10:30

Built Environment Conference 2026
BEC Listing
Networking
24 Sep 2026

Built Environment Conference 2026

08:30 - 13:00

Sub36 Awards 2026
Awards
16 Oct 2026

Sub36 Awards 2026

Park Hall Hotel & Spa , Chorley

18:00 - 00:00

LBV131 November/December Magazine Networking Event
Jan/ Feb Networking Event - Talking
Networking
19 Nov 2026

LBV131 November/December Magazine Networking Event

Lancashire

08:30 - 10:30

Lancashire Business Day 2026
LBD Listing
Networking
27 Nov 2026

Lancashire Business Day 2026

Burnley Football Club, BB10 4BX

12:00 - 17:00

Legacy & Leadership – Planning for Lift, Death and business continuity
Logo.jpg.jpg
LBV Hub Seminars
21 Jul 2026

Legacy & Leadership – Planning for Lift, Death and business continuity

Lancaster & Morecambe College, Lancaster, LA1 2TZ

09:00 - 10:30

Preston Freelancer Meet-Up July
LBV Hub Networking
21 Jul 2026

Preston Freelancer Meet-Up July

Society1, Coworking Space, Preston, PR1 3LT

10:00 - 12:00

Preston Tech Connection Coworking Day at Society1
PTC coworking day FB 900 Square.png.png
LBV Hub Networking
23 Jul 2026

Preston Tech Connection Coworking Day at Society1

Society1, Coworking Space, Preston, PR1 3LT

10:00 - 12:00

The AI Lab: Marketing Multiplier
LBV Hub Roundtables
31 Jul 2026

The AI Lab: Marketing Multiplier

Door4, Burnley Wharf, Manchester Road, Burnley, BB11 1JG

09:00 - 11:30

Chamber Breakfast Networking – August
Logo.jpg.jpg
LBV Hub Networking
04 Aug 2026

Chamber Breakfast Networking – August

Morecambe Golf Club, Morecambe, LA4 6AJ

08:00 - 10:00

Morecombe Bay Walk
Morecambe-25-web-gallery4.jpg.jpg
LBV Hub Fundraisers
08 Aug 2026

Morecombe Bay Walk

Arnside, Carnforth, LA5 0HD

13:00 - 18:00

The Ultimate Network
Logo.jpg.jpg
LBV Hub Networking
13 Aug 2026

The Ultimate Network

Garner Hotel , Preston, PR5 0UL

16:00 - 18:00

Advertise with us

Reaching 50,000 members, our print, digital and event platforms offer a fantastic way to raise your business profile and help you grow.

Find out more LBV124 Online Graphic
Subscribe now

Weekly news bulletin