DUAA 2025 compliance for a mobile app
Data (Use and Access) Act 2025. This page applies it to one kind of product (mobile app), so you get the obligations that are actually yours instead of a summary of the whole statute.
Does it apply to you?
Reform of the UK data regime: UK GDPR adjustments, cookies and automated decisions.
What a mobile app typically processes
- device identifiers and advertising IDs
- device permissions such as camera, location or contacts
- crash reporting and mobile analytics SDKs
- in-app purchases through the store
Each of these is processing you have to disclose. Adding an SDK later adds to this list — which is why a policy written once goes stale.
Documents you need
The intersection of what DUAA 2025 requires and what a mobile app actually does:
- Privacy policy
- Terms of service
Rights you must honour
DUAA 2025 gives people in the United Kingdom the right to:
- Access a copy of their data
- Correct inaccurate data
- Have their data deleted
- Receive their data in a portable format
- Object to certain processing
- Restrict processing
- Withdraw consent at any time
- Ask for human review of an automated decision
Cookies and trackers
Nothing non-essential may load before the visitor agrees. Analytics and marketing scripts must be blocked until then — a banner that only informs is not enough.
On mobile, the store asks too
There is no cookie banner in a native app, but Apple App Privacy and Google Play Data Safety both make you declare the same processing — and a declaration that contradicts your privacy policy is the version reviewers notice. The policy has to be reachable at a public URL before you submit.
See what your site is actually missing
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Primary sources
- DUAA 2025 — Data (Use and Access) Act 2025 · Information Commissioner's Office (ICO)
DUAA 2025 for other kinds of product
Other frameworks for a mobile app
This page is an engineering summary of publicly available regulatory requirements, generated from LexVibe's framework registry — not legal advice. Every framework links to its official text so you can check it yourself. For decisions about your own compliance posture, consult the primary sources and a lawyer qualified in the relevant jurisdiction.