Good Law Project v Reform UK: the data rights case that tests who can sue on behalf of others

In the weeks before the July 2024 general election, over 11,600 people used a tool built by the Good Law Project to send data subject access requests to the major political parties. Every party except one eventually dealt with the requests adequately. That exception was Reform UK, and the resulting litigation has now produced a judgement from Mr Justice Murray that matters well beyond its immediate facts.

Good Law Project Limited v Reform UK Party Limited [2026] EWHC 1458 (KB) is not about whether Reform breached GDPR obligations. That question is for trial. What the court was asked on a strike-out and summary judgement application was whether the Good Law Project has the legal capacity to bring this kind of representative action at all, and whether bringing it for what Reform characterised as political reasons amounts to an abuse of process. On both questions, Murray J found against Reform.

The mechanics matter here. Under Article 80 of the UK GDPR and section 187 of the Data Protection Act 2018, a body can bring a data rights claim on behalf of individuals it has been mandated to represent, but only if it meets specific conditions: it must apply all its income and capital to charitable or public purposes, must not distribute assets to members, and must have objectives that are in the public interest. It must also be actively working in the field of data protection.

Reform argued that the Good Law Project's Articles of Association did not satisfy these conditions. Several of the exceptions in those Articles, allowing payments to directors or connected persons for goods and services, were said to be irreconcilable with the requirement that all income be applied to charitable purposes. The judge rejected this. Paying a connected person a reasonable rate for goods or services is not a distribution of profit any more than paying a third party would be; what matters is that the expenditure is incurred in pursuance of the organisation's objects, which in GLP's case it must be.

On the public interest condition, Reform argued that some of GLP's objects, particularly its aim of addressing imbalances of economic power in the application of the law, represent sectional rather than public interests. Murray J declined to accept that characterisation and noted that the concept of public interest is broad enough to include significant areas of reasonable disagreement. Striking out a claim because two or three of an organisation's objects might be contested is not the right approach at this stage.

The abuse of process argument was more direct: GLP was said to be using private law litigation to advance a political agenda, specifically targeting a political party its founders and funders might oppose. The judge acknowledged that GLP may have an underlying political motivation, but held that this does not make the claim abusive. The Relevant Individuals have data rights; if those rights were breached and they suffered non-material damage as a result, they are entitled to relief. The fact that their mandated representative is a campaigning organisation does not change that.

The significance of the case reaches beyond the parties. Representative actions under Article 80 are still relatively rare in the UK and the conditions for standing have not been comprehensively litigated. This judgement establishes that an organisation structured as a company limited by guarantee, rather than a community interest company or charity, can in principle qualify, provided its constitutional documents properly constrain the use of its assets. It also makes clear that political motivation, even if present, is not a route to strike-out where the underlying legal claim is otherwise properly constituted.

What remains to be tested at trial is whether Reform actually breached its obligations and whether the 51 claimants suffered the kind of non-material damage, including distress, worry and uncertainty, for which Article 82 provides a right to compensation. That will be a harder question. But the door is now open.