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On 5 July 1993, The New Yorker published a cartoon by Peter Steiner of two dogs, one sitting on the floor and the other on a chair with its paw on the keyboard, with the caption "On the Internet, nobody knows you're a dog" (see On the Internet, nobody knows you're a dog Wikipedia). Part 2 of the Data (Use and Access) Act 2025 may change all that because it aims to regulate digital verification services in the United Kingdom.
In the Department for Digital, Culture, Media and Sport's press release, New legislation set to make digital identities more trustworthy and secure, of 10 March 2022, the previous government explained that digital identities are a new form of ID which can facilitate buying a house or starting a new job. An extensive consultation took place between July and September 2021, which resulted in legislative proposals on 11 Jan 2023. As I said in Data Protection Law Reform 23 Dec 2025, the previous government's Data Protection and Digital Information Bill fell with the government but many of its provisions were reintroduced in the Data (Use and Access) Act 2025.
The provisions for digital verification services appear between s.27 and s.55. S.27 (2) defines “digital verification services” as verification services provided to any extent by means of the internet. "Verification services" mean services that are provided at the request of an individual and consist in—
"(a) ascertaining or verifying a fact about the individual from information provided otherwise than by the individual, and
(b) confirming to another person that the fact about the individual has been ascertained or verified from information so provided."
The means by which those services are provided are listed in s.27 (1):
"(a) a trust framework (see section 28),
(b) supplementary codes (see section 29),
(c) a register (see section 32),
(d) an information gateway (see section 45), and
(e) a trust mark (see section 50)."
The DVS trust framework is a document prepared and published by the Secretary of State setting out rules concerning the provision of digitak verification services. The register is an annual register of businesses providing digital verification services. S.45 provides for information to be given to a registered person. The Secretary of States is required by s.50 (2) to publish a mark for use in the course of providing, or offering to provide, digital verification services. Only businesses on the register may use that mark and the Secretary of State may seek an injunction or interdict to prevent unauthorized use.
Anyone wishing to discuss this topic may call me on +44 (0)20 7404 5252 during UK office hours or send me a message through my contact page at any time.
