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Comment & Opinion

Technology & Digital round-up: 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.”

– Sally Mewies, Partner and Head of Technology & Digital

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Data reform at last!

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.

“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 B&W close up

£2 million+ ICO fine after cyberattack

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.”

Nick Stubbs black&white SMALL for TENDER digital version

– Nick Stubbs , Partner, Commercial

ICO launches AI and biometrics strategy

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.”

– Paul Armstrong, Director, Commercial

More legal and regulatory developments…

  • The ICO is consulting until 7 September 2025 on new draft guidance for manufacturers and developers of smart products.
  • Ofcom published its strategic approach to AI, setting out how it’s supporting the safe innovation and use of AI across the sectors it regulates.
  • It’s been reported that the EU could postpone implementation of some parts of the EU AI Act if, among other things, expected standards and guidance are not ready in time. The next major implementation date is 2 August 2025, when obligations concerning general-purpose AI models come into effect. We’re currently awaiting publication of the final code of practice, which should have been ready by 2 May 2025.
  • Meanwhile, the European Commission is consulting until 18 July 2025 on high-risk AI systems under the EU AI Act. The feedback, including practical examples, will be considered in upcoming Commission guidelines on classifying high-risk AI systems.
  • Amazon has given undertakings to the Competition and Markets Authority to curb fake reviews which are now explicitly banned under the Digital Markets, Competition and Consumers Act.
  • We’ve also seen the CMA issue guidance tips for businesses using dynamic pricing, and propose to designate Google with ‘strategic market status’ in general search and search advertising under the new digital markets competition regime.

…and in other news

  • The government finally published the UK’s Modern Industrial Strategy, described as a 10-year plan to significantly increase business investment in eight growth-driving sectors, including digital and technologies. The details are set out in a separate Sector Plan. The government’s vision is to make the UK one of the top three places in the world to create, invest in and scale-up a fast-growing technology business. It will prioritise these frontier technologies with the greatest growth potential: advanced connectivity technologies; AI; cybersecurity; engineering biology; quantum technologies; and semiconductors.
  • According to the government’s recent spending review, a Government Digital and AI Roadmap due in the autumn will set out the government’s digital priorities to deliver better public services.
  • The spending review confirmed a £750 million investment for Scotland to host the UK’s national supercomputer.
  • Ahead of the spending review, the government announced a £86 billion funding package for science and tech to turbocharge the economy.
  • The government announced new plans to supercharge the UK’s cyber sector.
  • We’ve seen a flurry of other recent announcements from the Department for Science, Innovation and Technology, including: the development of a digital marketplace to shake up how the UK public sector buys technology; an AI breakthrough to slash planning delays and help build 1.5 million homes; backing for ten AI innovations to help make the UK a clean energy superpower; and collaborative plans with leading tech firms to boost UK workers’ AI skills.
  • The National Cyber Security Centre launched its cyber security culture principles – guidance to support organisations in creating the right cultural conditions to enable their people to carry out the right security behaviours.
  • The BBC reported on Anglian Water saying that treated sewage, instead of drinking water, could be used to cool data centres. There are concerns that the growth of AI – powered by data centres – could lead to water shortages.
  • And finally, a Guardian investigation revealed that thousands of UK university students have been caught cheating using AI.

How we can support you

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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