Advocacy

Post date

25th September 2026

Our submission covers the following topics, following the government’s call for evidence:

  • How AI challenges the foundational assumptions of data protection law across the AI lifecycle — training, process and output.
  • The erosion of transparency and data subject rights (access, rectification, erasure, objection) where controllers can no longer identify what personal data they hold, how it’s processed, or what it produces
  • Risks from the “mosaic effect”, onward identifiability, and proposals to narrow the definition of personal data
  • Changes to automated decision-making (ADM) under the Data (Use and Access) Act 2025, including the shift in burden from controllers to data subjects
  • Regulatory gaps in the UK’s AI governance, including uses of AI that should be prohibited outright, such as live biometric identification, sentiment analysis, and behavioural prediction)
  • The intersection of competition and data protection, and the oversight gap around intelligence services’ data breaches under the Investigatory Powers Act