PASA publishes guidance on Data (Use and Access) Act 2025

The Pensions Administration Standards Association (PASA) has published a new industry paper, entitled The Data (Use and Access) Act 2025 Unpacked: Six key areas for pension schemes.

The paper provides a practical breakdown of the legislation and the accompanying materials from the Information Commissioner's Office, highlighting the most relevant implications for schemes.

The paper outlines six core areas that PASA says schemes need to understand and act upon:

• Automated decision-making.
• Digital Verification Services and the Trust Framework.
• Recognised Legitimate Interests.
• Subject Access Requests.
• Data protection complaints.
• The need for schemes to look ahead.

The guidance “provides useful direction for schemes seeking to interpret the changes and adapt their processes with confidence.”