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DUAA introduces a new complaints-handling requirement

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In an article first published in Privacy Laws & Business UK Report (November 2025), Annabel Gillham and Dan Alam analyse the UK’s...

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In an article first published in <a href="http://www.privacylaws.com/">Privacy Laws & Business</a> UK Report (November 2025), Annabel Gillham and Dan Alam analyse the UK’s upcoming data protection complaints-handling requirement — a change that will materially shift how organisations engage with individuals and the UK’s Information Commissioner’s Office (ICO) from June 2026. As they note in the article, “Prompt, transparent, and well-documented complaints-handling will be essential to meet ICO expectations, reduce regulatory risk, and build trust with individuals.” Read the <a href="https://media2.mofo.com/v3/assets/blt5775cc69c999c255/blt7064f2630f81cf32/6920a2acd6ca229cdd3757c7/251121-duaa-introduces-a-new-complaints.pdf" target="_blank">full article</a> (republished with permission from Privacy Laws & Business).

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Annabel is a partner at Morrison Foerster and co-Managing Partner of the London office. As a member of our renowned global data privacy team, Annabel specializes in employee data protection and data crisis management. Described by clients as “excellent, very pragmatic , efficient and completely client-oriented”, she works across a variety of sectors, including technology, retail, and financial services, and frequently manages multi-jurisdictional advice for international clients. Her practice includes advice on:<ul><li>cross-border labor and employment matters</li><li>employee litigation</li><li>data privacy compliance management</li><li>data security breach management</li><li>internal and regulatory investigations</li></ul>Annabel regularly helps senior management and HR executives with the “people” aspects of takeovers, restructuring projects, business and share sales, and outsourcings. She also advises employers in relation to sensitive claims, such as unlawful discrimination, equal pay, and whistleblowing. Annabel also advises on team moves.She supports her clients on all aspects of General Data Protection Regulation compliance and regularly advises organizations facing ICO enforcement action. She has developed particular specialties in complex areas, such as the collection and use of data relating to criminal offenses and the application of data protection law to insolvency practitioners.As an experienced litigator with experience in helping clients defend group litigation, Annabel helps clients develop their strategy for responding to regulatory action and court claims relating to the use of employee and customer personal data. She regularly designs and presents employment and data protection law training and updates to senior managers and HR executives and is involved in preparing responses to UK government consultations.In addition, Annabel is qualified to practice in the British Virgin Islands, where she spent three years advising on cross border commercial litigation and insolvency matters, including high value board and shareholder disputes, freezing orders, and third-party disclosure orders.

Annabel Gillham

Managing Partner, London

Dan Alam is a member of Morrison Foerster’s global Data, Cyber + Privacy Group, based in London. He provides advice to companies on various data‑related matters, including product counseling, regulatory investigations, security incidents, data transfers, litigation, mergers and acquisitions (M&A), and the development of robust data protection and AI compliance programs. Dan is recognized as a key lawyer in the Legal 500 UK (2024, 2025) for privacy, data protection and cybersecurity law.Dan regularly handles multijurisdictional projects and advises companies across various industries, including technology, semiconductors, interactive media, insurance, pharmaceuticals, hospitality, retail and logistics sectors.Dan has significant knowledge in employee privacy issues and the <a href="/gdpr-european-privacy/whistleblowing" target="_self">EU Whistleblowing Directive</a>. He has collaborated with several companies to design and implement global whistleblowing systems. Additionally, Dan supports companies in implementing their <a href="/capabilities/dei-strategy-defense" target="_self">diversity, equity and inclusion (DEI)</a> programs by advising on the collection and use of DEI data to support and advance DEI initiatives.  Examples of Dan’s other experience include:<ul><li>Advising technology companies on the launch of new products, including AI systems.</li><li>Conducting audits on the maturity of the data protection compliance programs of multinational companies.</li><li>Working with companies to respond to large-scale security incidents.</li><li>Providing support to companies on how to comply with cross-border data transfer and data localization restrictions.</li><li>Helping to respond to regulatory requests and investigations from the UK Information Commissioner's Office (ICO) and other EU data protection regulators, including in relation to direct marketing, individual rights requests, the collection and use of children’s data and data security incidents.</li><li>Advising on age assurance mechanisms and obligations under the UK Online Safety Act.</li><li>Defending companies against claims for compensation in respect of alleged breaches of privacy and data protection law.</li><li>Negotiating data processing agreements on behalf of companies acting as controllers and/or processors.</li><li>Providing specialist data protection and AI support on various public and private transactions, with particular experience advising on the acquisition of technology, semiconductor and AI companies.</li><li>Guiding employers on their employee monitoring practices and the collection of DEI data.</li><li>Participating in industry working groups to respond to government and ICO consultations on employee data protection issues and new UK data protection legislation.</li></ul>Before joining Morrison Foerster, Dan spent two months working at the Irish Data Protection Commission.Dan actively contributes to the firm’s pro bono initiatives by working for a variety of charities and NGOs, including by advising on social security and statelessness issues. He was part of the collaboration between Asylum Aid and various law firms that was recognized with the “Excellence in Pro Bono” Award by the Law Society of England and Wales in 2021 for work addressing the issue of statelessness in the United Kingdom. Dan is also co‑chair of the Morrison Foerster London ethnic minority <a href="/culture/diversity/affinity-groups" target="_self">affinity group</a> – MoFo Together.Dan is qualified as a solicitor in England and Wales.

Dan Alam

Associate

Data, Cyber + Privacy