UK GDPR & DUAA 2025 Compliance for Owner-Managed Businesses

Navigating data protection law as an owner-managed or small business doesn’t need to be overwhelming. The legal landscape—including the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and the Data Use and Access Act 2025 (DUAA 2025)—applies to all businesses, regardless of size.

At Whitestar Services Ltd, we specialise in making compliance practical, proportionate, and achievable—without unnecessary complexity or jargon.

Legal Duties: Do I Need a DPO or an SRI?

Under UK GDPR Article 37, a Data Protection Officer (DPO) is only mandatory for:

• Public authorities or bodies;
• Businesses conducting large-scale systematic monitoring;
• Those processing special category or criminal offence data at scale (Articles 9–10).

However, under Section 15 of the DUAA 2025, all data controllers must appoint a Senior Responsible Individual (SRI). The SRI must ensure lawful, transparent, and proportionate data use, manage access risks, and oversee breach governance—even where a DPO is not legally required. 

Common Data Protection Challenges for SMEs

1. Limited Resources
Many SMEs lack time, staff, or budget—yet remain fully subject to UK GDPR Article 5 (Principles) and Article 24 (Accountability).

2. Lack of Expertise
Business owners often overlook controller responsibilities under:

• Article 30 (Records of Processing),
• Articles 13–14 (Transparency), and
• Article 32 (Security).

3. Risk Management Gaps
Many fail to assess risks or conduct DPIAs (Article 35), leaving them exposed to legal and reputational threats.

4. Missing Documentation
Even small businesses must maintain:

• A Record of Processing Activities (Article 30),
• Privacy Notices (Articles 13–14),
• Retention Policies, and
• Supporting internal procedures.

These form the foundation of an effective Information Governance Framework.

5. Breach Response
Under Article 33, breaches must be reported to the ICO within 72 hours. TheDUAA 2025 adds further requirements to manage data access risks and incident accountability.

6. Subject Access Requests (SARs)
Fulfilling Article 15 and related rights (Articles 12–22) is time-sensitive. DUAA 2025 strengthens Access Management Principles, raising expectations on timely and lawful data access handling.

7. Ongoing Compliance
Compliance isn't one-and-done. Regular policy reviews, training, audits, and adaptation to new guidance (e.g. AI, children’s data, international transfers) are essential—but rarely feasible without external help. 

Whitestar Services: Practical Support You Can Rely On

We support UK businesses with tailored, cost-effective solutions:

• Appointed External DPO and Senior Responsible Individual (SRI) services
• Policy and documentation toolkits
• Breach planning and response support
• SAR management and compliance workflows
• DPIA facilitation
• Staff training and awareness campaigns
• Ongoing audits and advisory services

We simplify data protection—so you can focus on growing your business, with confidence that your legal obligations are met.