GDPR and AI: UK CISO Compliance Guide

UK GDPR continues to govern AI systems that process personal data in training data, prompts, retrieved context, logs, and outputs, despite amendments introduced by the Data (Use and Access) Act that largely took effect in February 2026. The reforms replaced Article 22 with Articles 22A–22D, allowing more lawful bases for certain significant solely automated decisions while retaining requirements for transparency, human intervention, representations, and contesting decisions, with stricter conditions for special category data. Commercial AI uses will generally still require a documented legitimate interests assessment, while AI developers face demanding expectations on training-data transparency, identifiability, and support for individual rights. Organisations must also acknowledge data-protection complaints within 30 days from June 2026, conduct DPIAs for high-risk AI processing, assess vendor roles and international transfers, and maintain records showing lawful basis, data minimisation, retention, security controls, and meaningful human review. The European Commission’s renewed UK adequacy decisions permit EU-to-UK data flows until December 2031, while the ICO is expected to issue a statutory AI and automated decision-making code in 2027.

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