1st July 2025
“Welcome to the July 2025 edition of our Technology & Digital round-up. This month we’re focusing on data: the long-awaited passing of new data legislation, a £2 million+ fine from the data regulator, and the launch of an AI and biometrics strategy as we see an uptick in regulator activity on AI. We also look at the 10-year plan for the tech and digital sector as the government launches the UK’s Modern Industrial Strategy.”
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The Data (Use and Access) Bill was finally passed into law after a much-publicised back and forth between the two Houses of Parliament on the issue of AI copyright. The Information Commissioner’s Office has published various guidance to support organisations and the public as the changes are introduced. They will be phased in between now and June 2026, with regulations awaited for some areas such as smart data schemes.
The ICO fined genetic testing company 23andMe £2.31 million for failing to implement appropriate security measures to protect UK users’ personal information. This followed a large-scale cyberattack in 2023. The data regulator found that the company failed to take basic steps to protect its customers’ sensitive information and its response was inadequate.
“This substantial fine is a stark reminder to organisations of their obligations under data protection law.
With cyberattacks an ever-present and evolving threat, organisations must be extra vigilant and make sure that they follow the ICO’s guidance and take proactive steps to comply with their security obligations.”
The ICO recently launched its AI and biometrics strategy. The stated aim of the strategy is to make sure that organisations are developing and deploying new technologies lawfully, supporting them to innovate and grow while protecting the public.
The Information Commissioner confirmed at the launch event that, over the next year, the ICO will consult on an update to its automated decision making and profiling guidance, develop a statutory code of practice on AI and automated decision making, and produce a horizon scanning Tech Futures report on the data protection implications of agentic AI (something we’ve talked about in previous editions).
“We’re really starting to see a ramping up of regulator activity on all things AI-related, as the government pushes forward with implementing its AI Action Plan.
As well as the ICO, the FCA is becoming a lot more visible in this space, launching a Supercharged Sandbox to help firms experiment safely with AI to support innovation. Both regulators recently highlighted how they’re working together to help firms use AI responsibly.”
If you have queries about any of the points covered in this edition of the Technology & Digital round-up, or need further advice or assistance, please get in touch with Sally, Andrew, Nick, Paul, Luke or one of our Technology & Digital experts.
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“Almost four years have passed since the Johnson government first consulted on post-Brexit data reform, but this new Data (Use and Access) Act doesn’t represent a radical overhaul of the data protection regime in the UK.
Among other things, the Act clarifies that you only have to make reasonable and proportionate searches in response to a subject access request. Changes to the cookie rules mean that you can set some types of cookies without having to get consent, but the widely hoped-for demise of cookie banners didn’t make it into the Act. There are also certain steps you have to take to help people who want to make complaints.
Our team is here to help with any queries on the Act and how it may affect you.”
– Andrew Northage, Partner, Regulatory & Compliance