What the New UK Digital ID Means for Data Protection and GDPR

The new digital ID scheme proposed for the UK is set to reshape how individuals prove their identity, interact with services, and manage personal data. These developments present both opportunities and challenges for data protection under UK GDPR, with wide-reaching implications for privacy, compliance, and governance.

What Is the New UK Digital ID?

The UK government is proposing a compulsory nationwide digital identity scheme, referred to as the “Brit card”, with the aim of tackling illegal working and streamlining the verification of the right to live, work, and access services in the UK. Unlike previous voluntary digital initiatives, this system is expected to become mandatory for all working adults, verified against a central database and potentially replacing various paper and document checks with a single, digital alternative. The response has been interesting with a petition created already with over 550,000 signatures in under 24 hours. 

Implications for Data Protection

The transition to digital identity changes the nature and scope of personal data held. The digital ID will contain sensitive personal information, including immigration, work, and housing status, making robust data protection measures imperative.

Lawful Basis and Transparency

Under UK GDPR, there must be a clear lawful basis for both the initial collection and ongoing processing of digital ID data. Organisations using or accessing the digital ID (employers, landlords, public sector) will need transparent privacy notices outlining how data will be used, stored, and shared. This means reviewing and possibly updating privacy policies and data processing records.

Data Minimisation and Purpose Limitation

Only the minimum data necessary for verification should be collected, used solely for its intended purpose, verifying identity or legal status—not for unrelated profiling or surveillance. Proposals cite Estonia’s model, where only the information required for a particular transaction is shared.

Security and Cyber Risk

A centralised, national identity database will become a high-value target for cyberattacks. Severe breaches could lead to major identity theft, fraud, and loss of trust. Data controllers must implement the highest level of encryption, access control, and breach mitigation in line with Article 32 of UK GDPR. Security must be at the heart of the system design from the outset.

Rights of Individuals

UK GDPR hands individuals rights including access, rectification, objection, and erasure, subject to certain exemptions. The digital ID must be built to allow individuals to view and control their information, challenge errors, and be promptly informed about how to exercise these rights.

Key Questions and Challenges

Digital Exclusion

An estimated 1.7 million older adults in the UK remain offline. Any digital ID system must offer non-digital alternatives to avoid discrimination and ensure accessibility for all

Scope of Access

Concerns persist that digital ID data could be repurposed for policing, commercial profiling, or broader surveillance. Without strict regulation, the risk of function creep is real. Clear legal boundaries and independent oversight are essential.

Data Governance

Robust governance will be needed to regulate data sharing between government departments, private sector, and third-party providers, as required by the Data Protection Act 2018 and GDPR.

What Should Organisations Do?

Update Privacy Documentation

Review all data protection documents and procedures to ensure compliance.

Conduct DPIAs

Undertake Data Protection Impact Assessments (DPIAs) before engaging with digital ID data, particularly when profiles or eligibility checks are automated.

Monitor Guidance

Stay alert for further guidance from the ICO on required safeguards and compliance steps.

Conclusion

The new UK digital ID system could streamline processes, combat fraud, and enable digital services, but only if deployed with privacy and security at its core. As data protection professionals, now is the time to prepare for new obligations: update policies, educate teams, and build trust in the responsible use of digital identities.

FAQs: UK Digital ID and Data Protection

1. What is the UK digital ID and why is it being introduced?

The UK digital ID is a new government initiative to create a secure digital identity for every adult. It aims to streamline identity verification for work, access to services, and compliance checks, and will likely become mandatory to tackle illegal migration and fraud.

2. How will the digital ID affect my personal data?

Digital IDs will contain sensitive personal information used for legal, financial, and service access checks. Organisations will need robust privacy controls and clear processes to comply with UK GDPR when handling this data.

3. What data protection risks could the digital ID pose?

Risks include potential security breaches, identity theft, misuse for profiling, and possible “function creep” (unintended wider uses). UK organisations must ensure strong cybersecurity, restrict data sharing, and only process data for legal, transparent purposes in line with the intended purpose for processing.

4. What rights do individuals have under UK GDPR regarding their digital ID?

Individuals have the right to access, correct, restrict, and erase personal data held within their digital ID, subject to exemptions. Organisations must provide clear guidance on how to exercise these rights.

5. Will my digital ID be used for other government or commercial purposes?

Under UK GDPR and the Data Protection Act 2018, data cannot be used for unrelated purposes without lawful basis and transparency. However, concerns remain about scope and governance, making robust regulation essential.

6. What should businesses do to comply with digital ID requirements?

Businesses should review privacy documentation, update processes, conduct Data Protection Impact Assessments (DPIAs), and train staff, ensuring they only use digital ID data for permitted purposes and respond promptly to subject access requests.

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