Empowering People Through Data Intermediaries — writing a response to the government consultation

Empowering People Through Data Intermediaries — writing a response to the government consultation

Every day we generate enormous amounts of data, and almost none of it sits with us. It sits with the organisations that collect it, and that imbalance shapes what we can know, what we can move, and what we can act on collectively.

Data intermediaries — data trusts, co-operatives, unions, personal data stores and others — have long been put forward as a way of rebalancing that relationship, by acting on people's behalf to exercise the rights they already hold but rarely use. The UK Government is now consulting on how to remove the barriers that have kept this sector small, and what the government does next will be shaped by the evidence it receives.

The consultation identifies three interlocking problems: legal ambiguity about whether data subject rights, particularly the right to portability, can be delegated to a third party at all; friction from data controllers who are unsure how to respond to requests made on someone else's behalf; and low public awareness of what intermediaries are for. It sets out seven options for addressing these, ranging from amending UK GDPR directly, through registration and certification schemes modelled on the EU and elsewhere, to voluntary codes of practice and new ICO guidance.

There is a lot at stake in how this is answered. The consultation is framed largely around market growth and individual empowerment, which leaves open questions about where collective and community-held models sit, what good governance actually looks like in practice, and who gets to be trusted with acting on someone else's behalf. Consultations are shaped by the people who take the time to respond, and this one deserves more than the usual voices.

What we'll cover

We'll begin with an overview of the consultation: what it proposes, why it is being run now, and how it sits alongside Smart Data schemes, the Data (Use and Access) Act 2025 and developments in the EU. We'll then spend time on how to write a response that actually gets read — how to use your own evidence and experience, which questions are worth prioritising, and the difference between an assertion and something a policy team can use. The remainder of the session is for questions and discussion, including working through the points people are thinking of making.

Who this is for

Anyone with a stake in how personal data is accessed, shared and governed: people building or running intermediary services, community organisations, researchers, civil society, public sector data teams, and anyone who holds data on behalf of others. No prior familiarity with the consultation is needed — come along and find out. The consultation can be found here

Be aware
Time is tight as this consultation closes on 31st August.