On 5 February 2026, the main changes to data protection legislation in Part 5 of the Data (Use and Access) Act 2025 (“DUAA) came into force.

The DUAA was passed and received Royal Assent on 19 June 2025. Although some of the DUUA provisions came into force automatically, many of the reforms

Continue Reading UK: Commencement of the data protection provisions in the Data (Use and Access) Act

In response to the UK’s new Data (Use and Access) Act 2025 (DUA Act) coming into force, the UK Information Commissioner (ICO) has launched two public consultations. The consultations, which aim to shape final guidance on amendments introduced by the DUA Act, address the new lawful basis of “recognised legitimate interests” 

Continue Reading UK: ICO launches consultations on the new Data (Use and Access) Act 2025

Introduction

The subject of “legitimate interests” and in particular whether they can be “purely commercial” has been a topic of front and center stage debate in the Netherlands for some time. The Dutch data protection authority (AP) has historically interpreted the concept of legitimate interest narrowly, taking the position that organisations

Continue Reading EU: CJEU Confirms that Legitimate Interests can cover purely commercial interests