29th May 2025 – The Data (Use and Access) Bill (DUAB) poses a serious risk to survivors of modern slavery. Drawing on lived experience testimony and practitioner research, our fact sheet outlines how key clauses on information rights within the DUAB—especially those in Part 5—threaten survivors’ access to justice, privacy, and support.
What does the Data (Use and Access) Bill mean for survivors?
- Subject Access Requests (SARs):
Clauses 77–78 would weaken survivors’ ability to access personal information needed to challenge poor decision-making by public bodies. Current barriers to SARs, including retraumatising identity verification practices, would be exacerbated. - Automated decision-making and AI:
Clause 80 removes the right not to be subject to solely automated decisions. This change undermines vital protections under UK GDPR Article 22 and could worsen already unreliable support processes like the National Referral Mechanism (NRM). Survivors would be left unable to request reviews of decisions made using incomplete or flawed data. - Expanded data sharing powers:
Clauses 70, 71, 74, and 85 enable broad expansions of data processing without independent oversight. This includes the re-use of personal data beyond its original purpose and the use of sensitive information for research without consent. Past data-sharing practices have already harmed survivors, including unauthorised use of private messages and police referrals to immigration enforcement.
Alongside Open Rights Group (ORG), we are calling for the removal of clauses 71, 72, 74, 77, 78, 80 and 84. We support amendments to strengthen complaint mechanisms through the ICO, especially for vulnerable individuals who would benefit from being represented by an organisation.
After Exploitation 