Tag: Employment

Thinking Differently: Why neurodiversity is a workplace superpower

Post author By Lousha Reynolds
Post date 17 March 2026
No Comments on Thinking Differently: Why neurodiversity is a workplace superpower

With it being Neurodiversity Celebration Week (16th–20th March), we felt that it was time to move beyond awareness and start talking more about action.

In the UK, it’s estimated that around 1 in 7 people are neurodivergent. This includes ADHD, Autism, Dyslexia, Dyspraxia, and Tourette’s, among others. For too long, recruitment processes and office environments have been designed around the “typical” brain. Often filtering out some of the most creative, analytical, and dedicated talent in the workforce.

From a British employment law perspective, supporting different ways of thinking is not only the right thing to do, but is also a legal requirement. To help business leaders and HR professionals, we’ve focused in on a few things to help better recognise and support neurodiversity at work.

1. Understanding the legal landscape: The Equality Act 2010

Under the Equality Act 2010, many neurodivergent conditions meet the legal definition of a disability, where that condition has a substantial, adverse impact on the individual’s ability to carry out their normal daily activities. In such cases, this means that employees have a right to protection from discrimination, harassment, and victimisation.

Crucially, employers have a legal duty to make reasonable adjustments. This duty is “proactive,” meaning you shouldn’t wait for an employee to reach a breaking point before offering support. By fostering an environment where adjustments are normalised, you stay ahead of legal risks and, more importantly, help your team thrive.

2. Redefining “reasonable adjustments”

Support doesn’t always mean expensive equipment. Often, the most impactful changes cost nothing but a shift in mindset. Effective adjustments often include:

Environmental tweaks: Providing noise-cancelling headphones, adjustable lighting, or quiet zones for deep focus.
Communication shifts: Giving instructions in writing rather than just verbally or allowing for camera-off meetings to reduce sensory overload.
Flexibility: Allowing for flexible start and end times to avoid the sensory stress of peak-time commutes.

3. Rethinking recruitment

The traditional hour-long, face-to-face interview is often a test of social performance rather than job competency. To support different ways of thinking, we can look at:

Skills-based assessments: Letting candidates demonstrate what they can do rather than just what they can say.
Clear job descriptions: Removing jargon and fluff (like “must be a great multitasker”) if it isn’t essential to the role.

4. Moving from “culture fit” to “culture enhancement”

In corporate culture, we often talk about culture fit. However, this can inadvertently lead to mini-me hiring, where everyone thinks and acts the same way.

To truly celebrate neurodiversity, we should look to add to our work culture. A neurodivergent employee might approach a problem from an angle no one else has considered. They might spot patterns others miss or bring a level of hyper-focus that drives a project to completion. Different ways of thinking are a competitive advantage.

How to get involved this Neurodiversity Celebration Week

This week is a fantastic opportunity to kickstart the conversation. You can:

Educate: Host a lunch-and-learn or share resources from the Neurodiversity Celebration Week website.
Listen: Create a safe space for employees to share their experiences (if they wish) and what support looks like for them.
Audit: Review your internal policies, from HR handbooks to your physical office layout, to see if they are inclusive of all brain types.

Neurodiversity isn’t something to be fixed or managed. It’s something to be celebrated. When we design a world that works for neurodivergent people, we inadvertently create a better, more flexible, and more productive workplace for everyone.

CONTACT US

We’re here to help with any questions or concerns you may have. Whether you need expert advice or would like an initial conversation about our services, pricing, or the options available, please don’t hesitate to get in touch. At Refreshing Law, what sets us apart from other law firms is that you’ll get to speak to an experienced employment lawyer right from the very first call.

02920 599 993

07737 055 584

lreynolds@refreshinglawltd.co.uk

GET IN TOUCH

Lousha Reynolds
Refreshing Law

Tags Disability, Disability Discrimination, Discrimination, Discrimination Law, Employee, Employment, Employment Law, HR, Neurodiversity

Employment Law Lousha Reynolds Press

Refreshing Law featured in Business Live

Post author By Lousha Reynolds
Post date 10 March 2026
No Comments on Refreshing Law featured in Business Live

Lousha Reynolds has been featured in Business Live.

Lousha recently took the helm of the firm, bringing over 17 years of expertise and a passion for straightforward, accessible legal advice. We’re excited to continue growing and evolving under her leadership.

Check out the article to learn more about Refreshing Law: https://www.business-live.co.uk/professional-services/refreshing-law-under-new-ownership-33552599

CONTACT US

02920 599 993

07737 055 584

lreynolds@refreshinglawltd.co.uk

GET IN TOUCH

Lousha Reynolds
Refreshing Law

Tags Business Live, Employee, Employment, Employment Law, Press

Acas Compensation Employment Law Employment Rights Act 2025 Kate Walsh Unfair Dismissal

Removing the statutory cap in unfair dismissal compensation: how will the UK compare to other countries?

Post author By Kate Walsh
Post date 5 March 2026
No Comments on Removing the statutory cap in unfair dismissal compensation: how will the UK compare to other countries?

The Employment Rights Act 2025 was passed late last year, and you will be forgiven for trying to catch up with all the proposed developments — there are so many! One of the most significant is the removal of the statutory cap for the compensatory award in successful unfair dismissal claims (the cap is currently the lower of 52 weeks’ gross pay or £118,223).

The statutory cap will be removed at some point in January 2027

From the information currently available to us, it is likely to be 1 January 2027 on the same date that the qualifying period for unfair dismissal is reduced from 2 years to 6 months.

Once removed, how will the UK fare when compared to a very employee friendly Europe?

In most European counties, unfair dismissal compensation is capped. The aim is simple: balance fairness for employees with predictability for employers.

Let’s look at the different regimes:

France link compensation to length of service. Awards start at around three and a half months’ salary (for two years’ service) and cap at 20 months’ salary, even for long-serving employees.

Switzerland limits compensation to six months’ salary.

Sweden caps awards at 32 months’ salary, depending on service.

Spain applies a formula of 33 days’ pay per year of service (for post-2012 hires) but again capped at 24 months’ salary.

Italy operates a dual system. Employees hired after March 2015 face capped awards of:

6 to 36 months’ salary for large employers.

3 to 18 months’ salary for small employers.

Following a Constitutional Court ruling, judges now have discretion within those ranges — but the cap remains firmly in place.

Ireland caps unfair dismissal compensation at 104 weeks’ total remuneration.

Denmark applies caps under collective agreements (up to 52 weeks’ pay) or six months’ salary for salaried employees, depending on service.

The common thread for most European countries — compensation is capped, and employers are able to plan negotiations accordingly. Beyond Europe, caps are still the norm. In Australia for example, the Fair Work Commission can award compensation for unfair dismissal but only up to six months’ salary.

The UK will be joining a handful of countries which have uncapped awards. In Luxembourg, judges are given a wide discretion with no fixed statutory cap. Canada has no formal statutory cap, but compensation is typically limited to damages reflecting the employee’s reasonable notice period, rather than open-ended loss. Lastly, in Brazil, employers are required to deposit 8% of the employee’s monthly salary into an account which is managed by the Federal Savings Bank on behalf of the employee. If an employee is dismissed without cause the employer must pay to the employee, (in addition to the payment of accrued rights and as a penalty for unfair dismissal) an amount equal to 40% of that which the employer has deposited into the employee’s severance compensation fund during their employment. The amount of the penalty will therefore depend on the length of employment and on the amount of the employee’s monthly salary.

It is clear that the UK will be joining the minority rather than the majority of countries who have uncapped unfair dismissal awards.

What are the repercussions of an uncapped compensation regime?

The statutory cap currently guides settlement negotiations with parties often negotiating around three to six months’ pay to avoid the time and costs attached to tribunal hearings.

Without the statutory cap:

Claimants may be more willing to take cases to a final hearing, adding to an overburdened tribunal system.
It is more difficult for employers to quantify the financial risk of a dismissal, which will inevitably impact settlement negotiations.
High earners are no longer deterred from lodging Tribunal claims meaning an increase in litigation for this group.
There is likely to be more complex remedies hearings that need to consider quantifying bonuses, deferred incentives and unvested equity.
Where the Acas Code applies, a potential 25% uplift suddenly bites harder when the underlying award is not capped.
On a positive note, it is likely to result in a reduction in more complex discrimination claims and whistleblowing claims as there will no longer be a need to bring these claims to avoid capped compensation.

How should you prepare?

Employers would be wise to start taking preparatory steps to tighten up procedures and ensure a clear document trail is in place. With an extended early conciliation period, plans to increase tribunal time limits for lodging claims and existing tribunal delays, tribunal witnesses will be placed under significant pressure to recall events which took place possibly two to three years ago. HR teams can make both their and witnesses’ lives a lot easier with clear processes and consistent decision making.

CONTACT US

GET IN TOUCH

Kate Walsh
Refreshing Law

Tags Acas, Compensation, Employee, Employment, Employment Law, Employment Tribunal, EU, European Union, Statutory Payments, Unfair Dismissal

Dismissal Employment Law Employment Rights Act 2025 Lousha Reynolds Notice Periods Probation

The top questions we’re hearing from clients this month

Post author By Lousha Reynolds
Post date 4 March 2026
No Comments on The top questions we’re hearing from clients this month

Although there are a raft of changes as a result of the Employment Rights Act (see ERA Timeline), undoubtedly the change that our clients have the most questions about is the reduction to the qualifying period for unfair dismissal from 2 years to 6 months, which takes effect on 1 January 2027.

The two most frequently asked questions this month relate to this and are as follows:

1. What impact do notice periods have on qualifying service under the new regime and do we have to include them when calculating qualifying service?

As long as the employee has a pay in lieu of notice clause within their contract and you exercise that right; i.e. you pay them in lieu of their contractual notice period, the contractual notice period does not get added to their period of service. However, for employees who have been employed for over a month but for less than two years, the law adds one week when determining their period of qualifying service. This means that even if you do exercise the contractual right to pay in lieu of notice, you need to factor in this additional notional week.

What that means in practice, is that you need to communicate dismissal decisions over a week before the six month qualifying period to avoid the employee being deemed to have 6 months service and a right to bring an unfair dismissal claim due to the notional week of service being added.

2. In view of the changes, what is the recommended duration for probationary periods?

We would advise between 3–4 months. For junior roles or where employees are on site full time/closely managed, a 3-month probationary period should be sufficient. You can also build in the ability to extend the probationary period for a further 6 weeks.

That said, we acknowledge that for the majority of our clients, it is difficult to properly assess suitability and performance within a 3-month period, particularly with hybrid working and for more senior roles. 4 months does still provide enough time for a short extension of the probationary period (we recommend 4 weeks) if this is required/or time in case meetings are delayed. However, where probationary periods are extended or meetings are delayed, it is important to remember to factor in the notional week referred to above to ensure that the employee does not have 6 months service at the time of the dismissal.

We recommend reviewing and updating the probationary periods in your existing contracts before issuing them to employees who commence employment on or after 1 July 2026. You should also check that your contracts include an appropriate pay in lieu of notice clause. In addition, it is vital to ensure that managers are fully briefed and trained on any changes to probationary periods and that they understand the importance of conducting the reviews in a timely manner.

CONTACT US

02920 599 993

07737 055 584

lreynolds@refreshinglawltd.co.uk

GET IN TOUCH

Lousha Reynolds
Refreshing Law

Tags Employee, Employment, Employment Law, HR, Notice, Notice of Termination, Notice Periods

Collective Redundancy Employment Law Employment Rights Act 2025 Lousha Reynolds Redundancy

Consultation launched on the threshold for triggering collective redundancy obligations

Post author By Lousha Reynolds
Post date 4 March 2026
No Comments on Consultation launched on the threshold for triggering collective redundancy obligations

Collective redundancy obligations currently arise where an employer proposes to make 20 or more redundancies within a 90-day period at one establishment. Different sites, stores and warehouses are generally treated as separate establishments. As a result, large-scale redundancies carried out across multiple sites may not trigger the duty to carry out collective consultation.

Many considered that this was unfair and so when the proposed Employment Rights Bill was first introduced by the Labour government, it included the complete abolition of the threshold at any one establishment. However, during consultation, significant concerns were raised and as a result the 20-employee trigger at one establishment is set to remain.

Instead, and at some point, in 2027, the ERA 2025 will introduce an additional, alternative threshold test based on the total number of redundancies across the whole business. This means that if redundancies are made throughout the UK at more than one location then collective consultation obligations will apply if more than a certain number of jobs are affected.

Last Thursday (26 February 2026), the Government launched a consultation on what this new organisation wide threshold for triggering collective redundancy obligations should be.

The Government is considering two options:

Using a single fixed number in the range of 250 to 1000.
Introducing a tiered system, based on the size of the employer:

250 redundancies for organisations with 0 to 2,499 employees.

500 redundancies for those with 2,500 to 9,999 employees.

750 redundancies for those with 10,000 or more employees.

The Government’s preferred approach is the single fixed number. This does appear to be the easiest way to ensure that employers understand their obligations, and that employees and trade unions are certain when they are entitled to participate in collective redundancy consultation.

Interestingly, the thresholds are much higher than many informed commentators predicted so perhaps this is an area where Labour are listening to concerns about the impact that the raft of reforms will have on businesses and the wider economy. If you want to engage in the consultation, it can be accessed via the following link here and is open until 21 May 2026.

CONTACT US

02920 599 993

07737 055 584

lreynolds@refreshinglawltd.co.uk

GET IN TOUCH

Lousha Reynolds
Refreshing Law

Tags Collective Redundancy, Employee, Employment, Employment Law, Redundancy

Employment Law Lousha Reynolds Video

Video | New look, same approach

Post author By Lousha Reynolds
Post date 10 February 2026
No Comments on Video | New look, same approach

The UK employment landscape is evolving fast. From new legislation to hybrid working models and workplace expectations, staying compliant while supporting your team can be challenging. At Refreshing Law, we provide clear, practical employment law guidance for businesses and HR teams. We can help with any employment law issues including:

Disciplinary and grievance procedures

Redundancy and restructuring planning

Discrimination and harassment issues

Contract and pay disputes

Our focus is on pragmatic advice that balances legal compliance with real-world business needs. So, you can make confident decisions and protect your organisation.

Watch our latest YouTube video to discover more about the Refreshing Law relaunch as we move into an exciting new chapter.

CONTACT US

02920 599 993

07737 055 584

lreynolds@refreshinglawltd.co.uk

GET IN TOUCH

Lousha Reynolds
Refreshing Law

Tags Employment, Employment Law, HR, Update, Video

Employment Law Lousha Reynolds Video

Refresh, reset

We’ve changed our look, not our approach

Now under the direction of experienced employment solicitor Lousha Reynolds, we’re pleased to introduce Refreshing Law’s new style.

We’ve rebranded, repositioned our social channels, and launched a new website, all to better reflect how we work and improve support for clients.

We continue to champion straightforward employment law advice, practical legal support, and clear guidance for employees, employers and HR teams. No jargon. No unnecessary complexity. Just lawyers who work for you.

Look out for more updates on our 2026 refresh and reset.

Refreshing Law | Voted one of the Top 200 legal practices in England and Wales by The Times

LOUSHA REYNOLDS

Lousha is a specialist, pragmatic employment lawyer, known for her personable approach and clear, practical advice. She helps clients navigate legal issues efficiently, focusing on achieving the outcomes that matter most.

Lousha has a wealth of experience in advising a diverse range of clients (both employers and employees) on the full spectrum of employment and HR related issues. She also has a proven track record at both the Employment Tribunal and the Employment Appeal Tribunal.

She has extensive expertise in:

Drafting contracts & policies
Disciplinaries, grievances, & managing dismissals
Redundancies, restructures, & change management
Performance management & absence management
Exit strategies: negotiating exits & Settlement Agreements
Tribunal litigation: unfair dismissal, discrimination & whistleblowing

Lousha took the helm of Refreshing Law in October 2025, following the retirement of Anna Denton-Jones, continuing our mission of straightforward advice and practical support for employees and employers alike.

READ MORE

VIDEO

CONTACT US

02920 599 993

07737 055 584

lreynolds@refreshinglawltd.co.uk

Get in touch

Lousha Reynolds
Refreshing Law

Tags Employment, Employment Law, HR, Update, Video

Employment Law Employment Rights Act 1996 Employment Rights Act 2025 Lousha Reynolds

Employment Rights Bill update — Where are we now?

Post author By Lousha Reynolds
Post date 29 September 2025
No Comments on Employment Rights Bill update — Where are we now?

The recent ministerial reshuffle, which saw the departure of three key supporters of the Employment Rights Bill (Angela Rayner, Justin Madders and Baroness Jones), left many wondering how this would affect the Bill’s progress. Questions were raised about whether the Government might water down or backtrack on some of the more contentious reforms, particularly the day-one right to unfair dismissal and new duties on employers regarding zero- and low-hours workers.

However, on 15 September 2025, the Employment Rights Bill entered its final parliamentary stages. The House of Commons rejected several significant non-government amendments proposed by the House of Lords, signalling the Government’s determination to press ahead with its core commitments.

Key developments in the Employment Rights Bill

Many of the proposed reforms raise questions about how they will operate in practice. While the Lords suggested several sensible amendments that could have simplified implementation, these were largely rejected, given their conflict with key Labour manifesto pledges.

Below is a summary of the main points:

Day-one unfair dismissal rights

The Bill abolishes the current qualifying period for unfair dismissal, introducing protection from day one of employment. This change adds complexity, particularly regarding the initial employment period and the scope of the proposed “light touch procedures.”
The Lords had proposed reducing the qualifying period to six months to simplify the system; a suggestion that was ultimately rejected.

Guaranteed hours contracts

The Commons reinstated the original duty on employers to proactively offer guaranteed hours contracts. The Lords had proposed a less stringent “right to request” model, but this amendment was not accepted.

Whistleblowing reforms dropped

Plans to extend unfair dismissal protection for whistleblowers and introduce new duties for employers to investigate disclosures have been removed from the Bill.

Right to be accompanied unchanged

Employees will continue to be entitled to be accompanied only by a trade union representative or colleague during disciplinary or grievance meetings. The Lords’ proposal to expand this to include a “certified professional companion” was rejected.

Ballot thresholds abolished

The requirement for a 50% turnout in industrial action ballots will be removed, despite efforts by the Lords to retain it.

Non-disclosure agreements (NDAs)

A ban on NDAs relating to complaints of discrimination and harassment was added to the Bill in July 2025. The Government has confirmed it will consult “as quickly as possible” on the secondary legislation required to implement this measure.

Next steps for the Employment Rights Bill

The Bill now returns to the House of Lords for consideration of the Commons’ position; a stage commonly referred to as “ping pong”, as both Houses must reach agreement before the Bill can receive Royal Assent.

Given that both Houses are in recess until 12 October 2025, Royal Assent is expected later in October. However, most major provisions, including reforms on fire and rehire, day-one unfair dismissal, and zero-hours contracts, are not expected to take effect until Autumn 2026 or 2027. Therefore, a short delay is unlikely to have any material impact.

What employers should do now

Although these significant reforms are a step closer to becoming law, much of the practical detail employers need will come through secondary legislation. The Government is expected to consult this autumn on key areas of change.

With so many reforms and ongoing uncertainty, it can be challenging for employers to stay up to date. We recommend:

Monitoring developments as the Bill progresses through Parliament
Preparing for upcoming consultations and future compliance obligations
Reviewing internal policies and procedures to identify potential areas of impact

We will continue to track progress and provide timely updates as new information emerges.

If you would like to discuss what the Employment Rights Bill 2025 means for your organisation, or how we can support you with tailored training, practical advice, or implementation planning, please get in touch at lreynolds@refreshinglawltd.co.uk.

Lousha Reynolds
Refreshing Law

Tags Employment, Employment Law, Update, Work

Anna Denton-Jones Employment Law Video

A goodbye from Anna Denton-Jones

Post author By Anna Denton-Jones
Post date 24 September 2025
No Comments on A goodbye from Anna Denton-Jones

On 1 September 2025, I reached a milestone of 25 years qualified. So, 27 years of being a solicitor and 25 years practising employment law post-qualification. To make you laugh we were the first year in which trainees were given a computer of their own. The year before four people had to share one: can you imagine suggesting that to anyone now?

Having grown up in the days of ordering company information from Companies House on microfiche (obtain a cheque, send a letter by post, wait for the fiche to come in a little cardboard envelope, load it into a machine the size of a filing cabinet, scroll through very difficult to read data) whereas now it’s a two second search on an app, I thought it might be interesting to reflect on what has changed over that time and what I’d like to see us promote.

The biggest changes are of course the technology: email and the internet was an infant and we treated email very much like a formal letter whereas now people stream consciousness at you like they are tweeting.

We live in an age where you can buy something from Amazon in the morning and have it delivered by afternoon. This comes with a pressure to think and act very fast (I remember the days where we could acknowledge receipt of a letter with a letter saying we’d received it and would respond, buying us at least 7 days time).

The greatest piece of advice I’d give anyone is to not get caught up in the frenzy. Unless you are up against a court deadline, building in a pause is helpful: it can give everyone the time to reflect and think differently. It can be easy to cave in to the clamour coming ‘at’ you to feel like you need to react immediately. When you do that oftentimes you’ll react with an emotional response… pausing enables you to give a more measured and thought through approach. At the very least breathe deeply before you respond. Not reacting is often a valid response as much as reacting is: you don’t have to buy into deadlines set arbitrarily.

The internet has upskilled the recipients of anything we send; they have a much better knowledge of anything we are communicating about and will challenge us accordingly; we’ve had to up our game. This is a good thing; we have to do better.

Attention spans are smaller. I used to have a twenty page redundancy document. I can’t imagine sending that document to anyone now. That’s probably a good thing. My client can read that information on the internet. We can focus on adding value.

This technology has made it all to easy to not communicate or to communicate badly. I remember the days when lawyers would routinely call each other, explain who they were acting for and have a ‘how are we going to sort this one out?’ call. Now all too often I am imploring my opposition to speak to me but it is easier to hide behind email. Conversations enable you to get a better understanding of where someone is coming from: that is as important in litigation as in life.

The same goes of managers too: the more they actually speak to people the better chance they have of addressing issues early doors before they fester. Have meetings, look each other in the whites of their eyes. It is harder for someone to maintain a complaint if they are feeling heard and listened to. It is harder to be angry if you are meeting with the human involved. So when someone sends an email and you gauge things might be getting tense, call a meeting, face to face if you can, Teams if you really have to, rather than respond with another email. Promote phone calls and meetings instead of email. If things are challenging like performance needs to be managed: have the conversation don’t hide behind digital processes. In fact that would be my parting shot: HAVE THE CONVERSATION! Apply it to everything.

I’m retiring so this will be my last blog. It will be interesting for someone to write another one in another 27 years, telling us how AI has changed the world for the good and for the worse. I’ll leave that to you.

Anna Denton-Jones
Refreshing Law

Tags Employment, Employment Law, Update, Video

Data Protection Act 2018 Data Use and Access Act 2025 Employment Law ICO Public Consultations Lousha Reynolds

ICO launches two public consultations on amendments to the Data (Use and Access) Act 2025 (DUAA)

Post author By Lousha Reynolds
Post date 9 September 2025
No Comments on ICO launches two public consultations on amendments to the Data (Use and Access) Act 2025 (DUAA)

In our previous blog we discussed the Data (Use and Access) Act 2025 (DUAA) and what it means for organisations. The ICO has since launched two public consultations to shape the final guidance on upcoming amendments to the DUAA.

The consultations focus on:

• a new data protection complaints process
• the new lawful basis of “recognised legitimate interests”

The consultations close on 19 October 2025 and 30 October 2025, respectively.

Looking at the handling of data protection complaints first, the ICO is keen for organisations to try and resolve complaints with individuals before they lodge a complaint with the ICO. To help achieve this aim, the DUAA requires all organisations to have a data protection complaints process in place by June 2026.

As part of this process, organisations must ensure they:

• provide a clear process for individuals to make data protection complaints
• acknowledge complaints within 30 days of receipt
• respond promptly and keep complainants informed throughout
• communicate the outcome without undue delay

The consultation seeks to understand whether additional clarity is needed to help organisations comply with the above.

The second consultation relates to the concept of ‘recognised legitimate interests’. The DUAA introduces new processing activities which carry the presumption of legitimacy.

These public interest activities include:

• crime prevention
• national and public security
• safeguarding
• emergency response
• sharing personal data to help other organisations perform their public tasks

The ICO’s draft guidance intends to support organisations by explaining how they may rely on the new legal basis and how the above conditions differ from the existing “legitimate interests” basis for data processing. The consultation seeks to understand whether further clarity is needed in this area.

How can employers prepare for changes under the DUAA?

Employers managing complex or large data subject access requests (DSARs) will inevitably feel the strain of completing a DSAR, to then have a complaint land on their desk. Of course it is not just DSARs which may invite complaints. Inadvertent data breaches can attract complaints from staff or customers/clients so it is important that all staff are reminded of their obligations when handling personal data to help reduce complaints.

Employers are understandably concerned that data protection obligations are about to become more onerous. To get ahead of the curve, employers are encouraged to:

• Review existing policies – what do you currently have in place and does this include a complaints policy?
• Review your existing reasons for processing data under the GDPR’s legitimate interest category and consult the guidance / seek advice on whether one of the new recognised legitimate interests can be relied upon.
• Offer refresher training to staff so they feel equipped to manage data protection issues and are aware of upcoming changes.
• Watch out for our further updates on this area.

If you would like to submit feedback on the consultations you can do so via the following links:

• The consultation on handling complaints closes on 19 October 2025.
• The consultation of recognised legitimate interests closes on 30 October 2025.

Lousha Reynolds
Refreshing Law

Tags Data Protection, DUAA, Employment, Employment Law, ICO