The Data (Use and Access) Act 2025: what employers need to do from 19 June 2026 (UK)

Data Protection Padlock

Based on a Privacy World blog by David Naylor, Robert Lister & Dan Fara, adapted for Employment Law Worldview by David Whincup

The UK’s data protection framework continues to evolve following the enactment of the Data (Use and Access) Act 2025. One of the more operationally significant developments for employers is the introduction of a new statutory right for employees to complain to controllers regarding infringements of the GDPR, as well as a framework governing how controllers must handle those complaints.

From 19 June, organisations subject to the UK GDPR will need to update their privacy notices and introduce formal data protection complaint-handling processes that meet specific legal requirements.

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Seventh Circuit Addresses Biometric Information Privacy Act (BIPA) Damage Accrual (US)

Many employers collect biometric data like retina or iris scans, voiceprints, hand scans, fingerprints, facial scans and DNA from their employees to track working hours, allow employee admittance to secure areas or provide access to pay stubs, among other reasons. The Illinois Biometric Information Privacy Act (BIPA) was enacted in 2008 to regulate and safeguard how private entities in Illinois handle biometric information, and imposes notice and consent requirements for the collection and storage of such data.

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EEOC’s Shifting Priorities and Strategies (US)

The United States Equal Employment Opportunity Commission (“EEOC”) is the nation’s primary workplace discrimination authority. Since its establishment as part of the Civil Rights Act of 1964, the federal agency has maintained jurisdiction over the investigation, mediation, and, in some instances, litigation of employment-based complaints.

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Labor Update: New House Bill Proposes Changes to Initial Union Bargaining Process and NLRB Inches Closer to a Three-Member Majority

Two recent developments in Congress signal potentially significant changes affecting labor law as we move further into 2026.

First, the House of Representatives passed the Faster Labor Contracts Act (H.R. 5408) on June 9, 2026. This bill would create a new process for negotiating collective bargaining agreements, in a way that significantly benefits unions. It would require employers to meet and begin bargaining with a union within 10 days after they receive a written bargaining request from a newly recognized or certified union. The parties must make “every reasonable effort” to reach an agreement during this initial period.

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Italy introduces employment law reforms

Italy recently introduced Decree-Law No.62/2026 which seeks to address three key areas: (i) the definition of “fair wages”; (ii) the restructuring of social security contribution exemptions as part of efforts to boost employment levels; and (iii) the protection of workers engaged through digital platforms.

  • (i) Fair wages

The most significant change is the introduction of a new concept of a “fair wage”.  Rather than setting a fixed minimum wage, the Decree defines a “fair wage” by reference to collective bargaining. 

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Reducing Legal Exposure When Managing Employee Performance Issues (US)

Effective performance management is not only a business necessity, but also one of the most important tools for reducing employment litigation risk. Few workplace decisions create more potential legal exposure than disciplining or terminating an employee for subjective performance-related reasons. In many cases, a lawsuit is not driven solely by the termination itself, but by poor (or non-existent) documentation, inconsistent treatment, delayed feedback or comments managers believed were harmless at the time. A poorly handled performance issue can quickly turn into claims of discrimination, retaliation, wrongful termination or wage-and-hour violations. By contrast, employers that take a consistent, proactive and well-documented approach to performance management are in a much stronger position to defend their decisions and avoid costly disputes.

Below are practical steps employers can take to manage performance issues effectively while reducing legal exposure.

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Italy implements the Pay Transparency Directive

Italian court

Italy has become one of the first EU member states to implement the Pay Transparency Directive. Legislative Decree 96/2026 came into force on 7June 2026, in accordance with the EU’s timetable. The Decree applies to both public and private sector employers, with some obligations differing depending on the size of the business. 

Below we provide a short overview of the new rules for Italian employers. As can be seen from this, Italy has stayed relatively close to the wording of the Directive and has not sought to “gold plate” the provisions. Its existing national collective bargaining agreement framework also plays a key role in the new pay transparency landscape, with such agreements providing the basis for assessing key concepts such as “same work” and “work of equal value”.   

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A party of no-shows? Implementation of the Pay Transparency Directive – A view across Europe

We know that with only a few days to go until the Pay Transparency Directive comes into force in Continental Europe, many companies are wondering what is going to happen, bearing in mind that only two EU member states have published final legislation implementing the full provisions of the Directive. 

Members of our Labour & Employment European team have, therefore, put together a short video providing details on the very latest position on local implementation in key EU jurisdictions, what it is likely to mean if a country has not yet implemented the Directive into its national law and the steps that affected companies should be taking now, bearing in mind the uncertain landscape.   

For more information on the Pay Transparency Directive and how we can support your business, please also visit our dedicated Pay Transparency Resources page on our website or speak to your usual Squire Patton Boggs contact or one of our experts: Janette Lucas, Marga Caproni, Malgorzata Grzelak,  Pauline Pierce, Laura Sparschuh, Chelsea Gunning or Elsa Mora.   

Another Blow to Mandatory Arbitration: Supreme Court Further Expands Transportation Worker Exemption Under the Federal Arbitration Act to “Last-Mile” Drivers (US)

Squire Patton Boggs’ Summer Associate Addyson Fry discusses a recent United States Supreme Court decision addressing the exemption under the Federal Arbitration Act applicable to transportation workers engaged in interstate commerce.

For decades, employers have relied on arbitration agreements to manage workplace disputes efficiently and predictably. But recent United States Supreme Court decisions have steadily narrowed when those agreements can be enforced under the Federal Arbitration Act (“FAA”).

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ECJ ruling on data subject access requests: Some welcome relief for European employers, or not quite yet? (Part II)

By: Marga Caproni, Chelsea Gunning, Lisa Shannon, Annette Demmel, Marmare Barekati, Malgorzata Grzelak, Floriane Essling and Marion Cavalier

Following on from our blog earlier in the week concerning the ECJ’s recent decision on data subject access requests (DSARs), we take a brief look at different European countries and the role that DSARs have come to play in these jurisdictions.

Belgium

In Belgium, DSARs are on the rise as a means of collecting information in preparation for a potential claim for unreasonable or discriminatory termination, or simply to put pressure on the employer to come to an agreement after termination, but this trend remains fairly modest and employers are certainly not being flooded with requests.

The Belgian Data Protection Authority has already had to rule on the excessive nature of (successive) requests, but it is generally quite accepting in this regard. Conversely, it is strict on employers: a request may be deemed excessive only if the aim is to harm the employer’s interests. The mere multitude of requests or the conflictual relationship between employer and (former) employee is not sufficient to refuse a request.

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