United Kingdom: Information Commissioner's Office closes consultation on draft updated guidance on storage and access technologies under Data (Use and Access) Act

On 26 September 2025, the Information Commissioner's Office closes the consultation on its draft updated guidance on storage and access technologies. The updated draft guidance outlines obligations following the adoption of the Data (Use and Access) Act 2025 and reflects changes to the Privacy and Electronic Communications Regulations (PECR). It explains how PECR and the UK GDPR apply to technologies that store or access information on user devices, including when this can occur without consent. The new chapters cover consent management and online advertising, while revised sections offer clearer language, updated examples, and new policy lines. The guidance uses “must”, “should”, and “could” to distinguish between legal requirements, expected practices, and optional measures. It focuses primarily on Regulation 6 and its interaction with the UK GDPR, where personal data is involved. The final version will be published after this second consultation, with further updates to the ICO guidance to follow.