The Coming GDPR Shake-Up: Why Public Sector Leaders Must Act Now

The story so far

A few years ago, artificial intelligence felt like science fiction — something confined to Silicon Valley labs or tech conferences. Then came the explosion of ChatGPT, Gemini and a wave of “free” AI tools. Within months, they had become the digital assistants of choice for millions of people — including those working in local authorities, NHS trusts, and central government.

Today, many public-sector professionals quietly rely on these tools to save time: drafting letters, summarising reports, or even cleaning data. When deadlines loom and resources are stretched, the temptation is clear — paste a spreadsheet into ChatGPT, get a summary from Gemini, or let AI rewrite an internal memo.

But this quiet revolution has also created a blind spot. In the rush to use AI, sensitive information — payroll details, HR records, even patient notes — is being uploaded to systems that were never designed to handle it.

A new era of digital accountability

The UK Government has recognised this reality. The Data (Use and Access) Act 2025, which amends parts of UK data-protection law, marks the start of a tougher era for public bodies. It updates GDPR-style requirements for the age of AI and data sharing, and introduces stronger expectations for accountability, transparency, and training.

At the same time, new guidance for civil servants and NHS staff makes one message crystal clear: no personal or sensitive data should be pasted into public AI tools.

The National Cyber Security Centre has echoed the same warning for those using their own devices — the “bring your own device” (BYOD) culture that has flourished since hybrid working began. Unmanaged devices and public AI systems create a perfect storm: data can be stored overseas, retained indefinitely, or reused for model training.

The result? A potential data-protection nightmare that no good intention can excuse.

What’s changing — and why it matters

Over the next 12 to 24 months, expect new rules, audits, and mandatory training requirements to appear across the public sector. Regulators such as the Information Commissioner’s Office (ICO) have already signalled that enforcement will ramp up. Fines of up to £17.5 million or 4% of global turnover remain possible — and the ICO has not hesitated to issue multi-million-pound penalties for basic security failures.

More realistically, we’ll see an increase in corrective orders, public reprimands, and compulsory action plans, especially for organisations that cannot show they have proper controls in place.

Behind the legalese lies a simple truth: AI is now part of everyday work — and so are its risks.

Public bodies can’t ban AI entirely, but they can’t ignore it either. The answer lies in learning how to use it safely.

The leadership challenge

This moment calls for a shift in mindset. Leaders must stop asking “Can we use AI?” and start asking “How do we use it responsibly?”

That means understanding where data goes, who controls it, and how it is secured. It means moving from vague policies to real action: approved tool lists, device management, red-line rules, and evidence of training.

AI is no longer a novelty. It’s infrastructure — and like any infrastructure, it needs maintenance, governance, and oversight.

The manager’s modern armoury

Compulsory AI-safety and data-protection training will soon become standard, not optional. The goal is not to turn everyone into a data-protection officer, but to make sure every employee understands the basics:

• what data can and cannot be shared,
• how to recognise high-risk scenarios, and
• where to turn for guidance.

Training is the guardrail that keeps innovation from tipping into chaos. It ensures the enthusiasm to use AI is matched by an equal commitment to protect the people whose data makes public services possible.

The leader’s checklist

To prepare for the coming changes, every manager should:

• ✅ Treat AI like any other business system — document, monitor, and audit its use.
• ✅ Approve tools centrally, and block public AI sites from handling sensitive data.
• ✅ Manage devices properly — encrypt, secure, and track who accesses what.
• ✅ Refresh staff training annually, and record completion rates.
• ✅ Ensure suppliers guarantee data protection and UK data residency.

A final word

Generative AI has transformed how we work. For many, it’s now as indispensable as email or search engines. But with that convenience comes responsibility.

Public services hold some of the nation’s most personal information — from medical histories to social-care records. Protecting that data is not just a legal duty; it’s a matter of trust.

The next phase of AI adoption will be about guard rails, not guesswork — and leaders who build that culture now will be the ones who help their organisations innovate safely, responsibly, and confidently.