Data Privacy Week 2026: Practical Privacy Trends for UK Organisations

Each January, Data Privacy Week provides a useful opportunity to pause and take stock. Not just of legal requirements, but of how data protection is actually working inside organisations.

In 2026, that pause feels particularly necessary.

Over the past year, data protection has continued to move away from static compliance documentation and further into day‑to‑day operations. The Data Use and Access Act, increased employee awareness of data rights, more routine use of AI tools, and ongoing cyber incidents all have one thing in common. They test whether privacy processes work in practice, not just on paper.

For many organisations, Data Privacy Week remains an awareness exercise. For others, it has become a practical checkpoint. Are data protection decisions consistent, proportionate, and explainable? Are teams confident applying the rules? Is governance keeping pace with how data is actually used?

This year, those questions matter.

Why Data Privacy Week Still Matters in 2026

Data Privacy Week runs from 26 to 30 January, with a focus on control, responsibility and trust. These themes resonate because individuals are asking better questions about their data, while organisations are managing far more complex environments.

Within UK organisations, we see this tension play out most clearly through:

• Increasing volumes of data subject access requests, particularly from employees
• Greater scrutiny of AI and automated decision making
• Higher expectations of proportionality rather than exhaustive processing
• Pressure to evidence decisions, not just outcomes

Awareness alone is no longer sufficient. Regulators, courts and individuals increasingly expect organisations to demonstrate how data protection works in practice.

The DUAA and Practical Proportionality

One of the most important developments shaping data protection in 2026 is the Data Use and Access Act. While the Act does not replace UK GDPR, it gives statutory weight to ideas that previously sat in guidance and case law.

Most notably, the DUAA reinforces that organisations are expected to take reasonable and proportionate steps. This is particularly relevant for subject access requests, where many organisations have historically acted far beyond what was necessary due to uncertainty and risk aversion.

Proportionality now has clearer legal footing. However, that only helps organisations who can show:

• How data sources are identified and prioritised
• Why certain systems are included or excluded
• How decisions are made and reviewed
• That staff are trained to apply this consistently

Without that context, proportionality becomes difficult to defend after the fact.

DSARs: Volume Is Only Part of the Issue

Data subject access requests continue to rise across the UK, but volume alone is not the main challenge.

What we increasingly see is a shift in how DSARs are used. In employment contexts especially, requests are often submitted alongside grievances, disciplinaries, or tribunal claims. In many cases, the request itself is not the end goal. It is part of a wider strategy.

Organisations frequently tell us they are confident in meeting deadlines, but less confident in:

• Applying consistent scoping across cases
• Coordinating responses between HR, IT, Legal and the DPO
• Explaining why certain data was not searched or disclosed
• Defending decisions when challenged

The DUAA helps by legitimising proportionate approaches, but it also raises expectations around governance and documentation.

AI Governance: A Common Area of Uncertainty

AI features heavily in privacy conversations during Data Privacy Week, but often without much clarity.

A recurring example from our work illustrates this well. We are regularly asked to help with AI governance, but without a clear definition of what that is meant to cover. In one recent engagement, the organisation knew AI was being used across HR, marketing and operations, but could not confidently answer basic questions such as:

• Which tools were approved and which were informal
• Whether personal data was being used for training or prompts
• What lawful basis applied to specific uses
• Whether any DPIAs had been completed
• Who was accountable for decisions involving AI outputs

This is common. AI governance is often discussed as a future requirement, but the risk already exists in day‑to‑day usage. In many cases, the issue is not a lack of technology, but a lack of clarity around ownership, purpose and limits.

From a data protection perspective, existing principles still apply. Transparency, purpose limitation, accuracy and accountability remain central. AI does not remove those obligations.

Cybersecurity and Privacy Are Operationally Linked

Another clear trend entering 2026 is the continued convergence of cybersecurity and data protection.

Cyber incidents now almost always involve personal data. As a result, weaknesses in access control, logging, segregation or supplier management are routinely treated as data protection failures rather than purely technical issues.

In practice, this means privacy teams are increasingly involved in:

• Incident response planning
• Risk assessments for new systems
• Vendor due diligence
• Governance discussions at Board or senior management level

We see the strongest outcomes where privacy and security teams work together, using shared language and shared evidence rather than operating in parallel.

Internal Trends We See Across Organisations

Looking across our work with clients, several consistent internal patterns stand out at the start of 2026.

First, data protection is increasingly recognised as a leadership responsibility. Senior teams are asking more detailed questions, particularly around employee data, AI use, and reputational risk.

Second, organisations with comprehensive policies but limited operational guidance are the most exposed. Staff often want to do the right thing, but lack practical direction.

Third, tooling alone does not solve governance issues. Platforms such as Microsoft Purview and Priva are effective when implemented within a clear framework, but they do not replace decision making or accountability.

Finally, training is shifting away from generic GDPR awareness and towards role‑specific sessions focused on real scenarios.

Using Data Privacy Week as a Practical Checkpoint

Data Privacy Week does not need to be a major campaign to be useful.

Used well, it can provide a practical reset. A moment to ask whether current approaches still reflect how data is actually used across the organisation.

This might include:

• Reviewing how proportionality is applied in practice
• Stress testing DSAR workflows
• Mapping current AI usage and responsibility
• Checking whether governance documentation reflects reality
• Updating training for those handling higher‑risk data

Perfection is not the goal. Consistency, clarity and defensibility are.

How GRC Hub Supports Data Privacy in Practice

GRC Hub works with organisations across data protection, AI governance and cybersecurity precisely at these operational points.

This includes DPO and Privacy Manager support, DSAR governance and handling, AI oversight and DPIAs, incident response, and targeted training. The focus is always on helping organisations make proportionate decisions and be able to explain them.

If Data Privacy Week highlights uncertainty rather than confidence, that is often a useful signal. Addressing it early is almost always easier than responding under pressure later.

  Contact us for expert help.