How does the UK digital identity framework implement data minimisation and purpose limitation for worker records?
Executive summary
The UK’s trust framework and related laws aim to enforce data minimisation and purpose limitation for digital identity, mainly by making identities “reusable” so relying organisations do not re-collect original documents and by requiring certified providers to follow ICO minimisation guidance and not collect demographic data solely for inclusion reporting [1] [2]. The trust framework came into force 1 July 2025 and is on statutory footing through the Data (Use and Access) Act 2025; certified providers must complete inclusion monitoring reports and follow standards covering privacy and verification practices [3] [1] [2].
1. How the framework reduces what employers must collect — “reuse, don’t re-request”
The trust framework enables reusable digital IDs so an identity service provider’s verification can be accepted as authoritative; when employers or other organisations accept that verification they “do not need to do it again themselves,” which in practice reduces how much personal data employers receive during right-to-work or onboarding checks [1] [4]. Industry commentators and provider literature describe the same effect — digital credentials let organisations receive just a verified attribute rather than full identity documents, which is framed as facilitating data minimisation [5] [4].
2. Statutory and standards backbone: Data Act + trust framework
The system is not only voluntary technical guidance: the trust framework was placed on statutory footing by the Data (Use and Access) Act 2025 and the published trust framework documents set explicit standards for verification process, privacy, cybersecurity and inclusivity that certified providers must meet [1] [4] [3]. That legal and standards architecture is the mechanism by which the government seeks to bind providers to minimisation and purpose-limited uses in practice [1] [3].
3. ICO principle baked into reporting and certification
The Information Commissioner’s Office (ICO) data minimisation principle is explicitly referenced in the trust framework and in related inclusion monitoring guidance: certified digital verification services are told that the ICO’s minimisation principle must guide their approach and the framework states services “are not required to collect information on users solely for the purposes of inclusion reporting” [2]. Certification and the requirement to produce inclusion monitoring reports create an auditable trail linking practice back to ICO expectations [2].
4. Technical design choices that support minimisation — what sources mention
Sources point to reusable credentials and selective sharing of verified attributes as the core technical means of minimisation: instead of employers receiving scans of passports or full identity documents, they can receive a verified attribute (e.g., “right to work: yes”) issued by a certified provider [1] [5] [4]. Provider and government publications position the GOV.UK Wallet and One Login as part of this architecture that limits what data is shared at point of use [1] [6].
5. Purpose limitation: rules, but enforcement depends on certification and contracts
The trust framework sets standards intended to limit uses of identity data to stated purposes and to ensure providers meet privacy and cybersecurity requirements [1] [3]. The Data (Use and Access) Act and certification regime are the government’s tools to formalise those limits [1]. Available sources do not mention the detailed enforcement mechanisms employers would face if they misuse data beyond saying certified providers must meet privacy standards (not found in current reporting).
6. Where tensions and gaps appear in the reporting
Reports trumpet minimisation through reusability, but several practical tensions persist in the sources: inclusion monitoring requires demographic data in some contexts (even though the framework says services “are not required” to collect it solely for inclusion reporting), meaning that some collection beyond bare minimums may occur for market monitoring [2]. Sources also note the Wallet will store government documents and that data will be hosted in UK datacentres or cloud environments — hosting choices may affect perceived risk even if they do not change the minimisation principle itself [7] [6].
7. Industry and provider claims vs. public scrutiny
Industry and identity-provider commentary underline minimisation benefits (digital IDs avoid handing over whole documents) and welcome registers and trust marks that signal certified services [5]. Independent briefings note the same benefits while mapping the statutory framework [4] [1]. Public pushback and concerns about surveillance are referenced in later reporting but are not detailed in these sources — available sources do not mention the scale or outcomes of public opposition in detail here (not found in current reporting).
8. Bottom line for employers doing worker checks
Under the current framework, employers can rely on certified digital identity providers’ verified attributes and therefore should receive less raw personal data when performing checks; providers are bound by trust-framework standards and ICO minimisation principles and must produce inclusion monitoring as part of certification [1] [2] [3]. How strictly purpose limitation is enforced against end-user organisations is framed by certification and the Data Act, but the sources do not give granular enforcement scenarios for employers (not found in current reporting).