Don’t Sleep on UK Data Privacy: The UK GDPR, PECR, and the New DUAA

Why Global Businesses Must Pay Attention to Evolving UK Privacy

Over the last 7 years, companies have focused on EU GDPR, U.S. state privacy laws, and other international privacy laws. But often, they are overlooking the growing complexity of data protection compliance in the United Kingdom. The UK is sharpening its post-Brexit regulatory landscape, and businesses can no longer afford to treat UK privacy obligations as an afterthought.

In 2025, three legal frameworks are shaping the future of UK data governance: the UK GDPR, the newly introduced Data Use and Access Act (DUAA), and the long-standing but increasingly relevant Privacy and Electronic Communications Regulations (PECR). Together, these laws will define how companies doing business in the UK collect, use, store, and share personal information. And, as these laws evolve over the next few years, there will be new compliance burdens for global brands doing business with UK consumers.

This article outlines what each law means, why companies from around the world are directly affected, and how Clarip can help streamline compliance for modern organizations.

The UK GDPR is Familiar, Yet Different

The UK GDPR, inherited from the EU GDPR post-Brexit, may look similar on paper, but organizations often fail to appreciate its unique enforcement environment and evolving interpretations. Since leaving the European Union, the UK has gradually begun carving its own path in data protection. The Information Commissioner’s Office (ICO), the UK’s regulator, has signaled its willingness to pursue enforcement actions and to issue its own guidance, separate from the EU.

Companies must be mindful of these distinctions. What satisfies a Data Protection Authority in Europe may not be sufficient in the UK. For example, international data transfers require a UK-specific International Data Transfer Agreement (IDTA), and UK representative requirements still apply to non-UK companies targeting UK users.

Organizations that treat the UK GDPR as merely an extension of the EU regime risk falling into non-compliance. Especially as enforcement patterns and interpretations begin to diverge.

The Potentially Overlooked Importance of PECR

The Privacy and Electronic Communications Regulations, or PECR, governs electronic marketing, cookies, and communications infrastructure. Despite being in effect since 2003, PECR remains one of the most misunderstood and under-enforced privacy laws – until it isn’t. The ICO has repeatedly fined companies for unsolicited emails, calls, and inadequate cookie consent.

What many businesses miss is that PECR applies even if no personal data is involved. That means if your company uses cookies for analytics or tracking or engages in email or SMS marketing to UK users, PECR is in play regardless of GDPR considerations.

PECR and the UK GDPR will operate in tandem. A valid lawful basis under one law doesn’t guarantee compliance with the other. For example, using “legitimate interest” under GDPR for marketing might still breach PECR if prior consent hasn’t been obtained. These distinctions can create compliance traps for companies that adopt a one-size-fits-all approach. This reinforces the need for adopting consent solutions tailored to specific needs.

The Data Use and Access Act of 2025

The UK’s Data Use and Access Act (DUAA), coming into full effect in 2025, marks a major shift in how data is shared between organizations and the public sector. Designed to improve interoperability and unlock the value of data across industries, the Act introduces new duties for businesses, especially those operating in sectors like health, energy, education, finance, and logistics.

One of the most significant features of the Act is its requirement for organizations to share certain datasets with public authorities under defined conditions. This goes beyond traditional privacy compliance. It forces companies to consider new data governance standards, auditability, and transparency.

For global businesses, the DUAA means that UK data isn’t just subject to privacy regulation. It is also subject to mandatory sharing, especially if it intersects with public interest initiatives. Companies will need to reconcile these obligations with their internal data handling policies and any contractual or legal constraints on cross-border data movement.

Who Should Pay Attention to The Global Stakes

The UK remains one of the world’s most important markets, both as a standalone economy and as a digital gateway to Europe. A wide range of global companies conduct business with UK residents, and many do so without a physical presence. Whether it is through digital commerce, targeted advertising, SaaS platforms, and third-party data processing relationships, these interactions routinely bring multinational organizations within the scope of UK law.

Firms based in countries like the United States, Germany, France, India, Japan, and China, among others, frequently operate within UK jurisdiction simply by virtue of their online activities. The UK’s extraterritorial provisions means that if you target or monitor UK residents, you are likely subject to its privacy laws.

The consequences of non-compliance are real, lasting, and increasingly difficult to reverse. While organizations often hear warnings about reputational harm and financial penalties, the true impact runs deeper. We’ve seen firsthand how regulatory missteps lead to long-term financial risk, operational setbacks, and loss of consumer trust. In today’s environment, where overlapping laws like the UK GDPR, PECR, and the DUAA are enforced by active regulators, companies can no longer afford to treat UK privacy compliance as optional, secondary, or part of European privacy as a whole. The cost of falling behind is only growing.

The reality. Failure to proactively align with UK-specific requirements, especially under PECR and DUAA,can disrupt product launches, derail growth plans, and tarnish a brand’s ability to operate in the broader European digital ecosystem.

The urgency is clear. The UK regulatory environment will mature and diverge from the EU. Multinational companies must act now to localize their compliance strategies. Waiting too long, or assuming GDPR compliance is “good enough”, will invite undue risk at precisely the moment UK enforcement is stepping up.

Why Clarip is the Right Solution for UK Compliance

Navigating the complexities of UK GDPR, PECR, and the DUAA is a legal and operational challenge. Compliance requires more than awareness. It demands coordination across legal, marketing, IT, and governance teams, backed by reliable technology and scalable processes.

Clarip offers a unified, intelligent privacy operations platform designed specifically to meet the evolving demands of modern data protection laws. Our solution empowers companies to streamline compliance across all facets of UK privacy regulation. This is from managing cookie consent and marketing permissions under PECR to automating Data Subject Access Requests (DSARs) in line with the UK GDPR’s timelines and requirements.

What sets Clarip apart is its ability to adapt to emerging laws like the DUAA. With Clarip, organizations can track where data resides, how it is shared, and whether it falls under new data-sharing mandates. Your organization remains transparent, accountable, and audit ready.

For companies doing business in the UK, whether directly or digitally, Clarip provides the tools, insights, and automation needed to reduce risk, build trust, and operate with confidence in a shifting regulatory landscape.

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Mike Mango
COO & SVP, Enterprise Accounts
mmango@clarip.com
(646) 983-4618