Legislation in force · general processing

The framework has changed

Section 80 of the Data (Use and Access) Act 2025 replaced UK GDPR Article 22 with Articles 22A–22D. The new approach distinguishes significant decisions involving special-category personal data from those involving other personal data. The relevant general-processing changes commenced on 5 February 2026. [1] [2]

Automation does not remove the safeguards

A decision is solely automated when it involves no meaningful human involvement. It is significant if it has a legal or similarly significant effect. The safeguards include information about the decision, an opportunity to make representations, human intervention and a way to contest it. Stricter restrictions remain for special-category data; ordinary data-protection duties still apply. [1] [3]

ADM perspective

A useful governance question is what a person can actually do after receiving an automated outcome. A policy promising oversight is less useful than a review process with a responsible person, relevant evidence and the ability to change the result. Treat that as an operational design question as well as a legal one.

Read the original sources

The original publications provide the full detail, evidence and limitations.

  1. UK Parliament · Legislation commentaryData (Use and Access) Act 2025 — Section 80 explanatory notes
  2. UK Government · Commencement regulations · PDFCommencement No. 6 Regulations 2026
  3. Information Commissioner’s Office · Regulator explanationDUAA: data protection changes

An AI-assisted, source-led summary. “ADM perspective” is editorial interpretation, separate from the source’s findings. This is general information, not legal advice. Our editorial approach.