LearnDash UK GDPR Compliance 2026

In this article, I will cover everything you need to know to make a LearnDash-developed course platform compliant with the UK GDPR in 2026.

My name is Wellington Duarte, a LearnDash developer focused on the UK. I hope this article is useful to you.

In 2016, the GDPR (General Data Protection Regulation) was approved by the European Union, and in 2018 it came into full effect.

The focus of the GDPR is to require companies to handle personal data on the internet responsibly.
All of this became necessary due to scandals involving major companies and data breaches affecting users, both in Europe and in other countries. Just to refresh your memory:

Yahoo 2013 – Even though it is an American company, it suffered two major attacks between 2013 and 2014, compromising 3 billion accounts. As the GDPR was not in force at the time, the fines applied by European data protection authorities were considered insignificant compared to the damage caused.

The ICO (Information Commissioner’s Office) issued a fine of only £250,000 in 2018, the maximum limit under the previous law. This case was considered one of the most serious incidents in the history of the internet. These user data are used for state espionage, sold on the dark web for $200,000 or more, used in email spam campaigns, and for phishing to steal banking information. As many users reused the same password across multiple websites, criminals were able to use leaked “email and password” combinations to access other platforms.

You can read more about this scandal here.

Other major breaches occurred before the GDPR was created, such as the TalkTalk case and Ashley Madison in 2015, and Cambridge Analytica, revealed in 2018, shortly before GDPR enforcement. This case was a catalyst for public support for stricter regulation.

With all of this happening, a massive effort was needed within the European Union to address these issues.

GDPR in the United Kingdom after Brexit

Between 2020 and 2021, the United Kingdom left the European Union. So what happens to GDPR in this case?

The UK decided to largely retain the same law, creating the British version called the UK GDPR. In addition to being an extremely important regulation that inspired similar versions around the world, it was essential to maintain it so that the UK could continue sharing data with European companies.

In the UK, things have remained largely the same, such as:

• Websites must request permission before using user data.
• Explain how this data will be used.
• Protect this information from breaches.
• Delete this information if the user requests it.

How does the UK GDPR differ from the GDPR?

• Supervision is no longer carried out by the EDPB, but by the ICO;
• Creation of the IDTA (International Data Transfer Agreement) for transferring data outside the UK, instead of the EU SCCs;
• Autonomy to decide which countries are considered safe, independently from the EU;
• Ongoing efforts to remove the requirement for a DPO (Data Protection Officer), allowing for a “responsible individual”, reducing bureaucracy;
• Facilitation in the use of cookies, etc.

This is why it is very important to understand the evolution of these laws when building a course platform with LearnDash on WordPress, especially since the EU does not want the UK to overly relax its regulations.

That is why it is important to talk about the DUA.

What is the DUA Bill – Data Use and Access (DUA) Bill?

The DUA Bill (Data Use and Access Bill) is a proposed UK law that aims to relax certain UK GDPR rules, making it easier to use “non-intrusive” cookies such as analytics cookies. Once approved, it becomes the Data Use and Access Act (DUAA).

In summary, it represents the UK trying to make data usage rules more practical for businesses, without abandoning user protection, while reducing bureaucracy.

It is important to understand that the DUA does not eliminate the UK GDPR; it is merely a complement or update to the law, changing the following:

• Some cookies can be used without explicit consent;
• For marketing campaigns, the use of databases is based on the user’s “legitimate interest”, reducing fear around data usage;
• Use of data for AI, previously considered risky, now has clearer rules focused on research and innovation;
• Less internal bureaucracy within companies – previously, they had to maintain extensive documentation and slow processes, which have now been simplified.

To learn more about all the changes introduced by the DUA, click here.

How should a LearnDash course platform be protected?

It is important to understand that rules for course platforms in the United Kingdom are strict, and a LearnDash developer must be aware and up to date, as non-compliance can result in significant fines.

What data does a LearnDash course collect?

• User’s full name
• Email address
• Course progress
• Grades and performance
• Study time
• Sometimes: location, IP address, and behaviour within the platform

Generally, these are the main data collected. If you expand into a course + community platform (e.g. BuddyBoss), the volume of data increases. This is already considered relevant personal data that requires protection.

Learn more about the data that LeanDash collects here.

What the ICO requires for online courses

• A contract confirming and guaranteeing course delivery;
• User consent – if their data will be used for marketing and promotional emails.

In this case, you may use the user’s email to send course access information, and if they opt in to marketing, you may send promotional content. However, sending spam without permission is not allowed.

You must have a clear Privacy Policy page (no generic templates), explaining:

• What data your course platform collects, why it collects it, how it is used, and with whom it is shared.

User control

• Allow students to request a copy of their data, correct their information, and request deletion. This is mandatory.

Data security in LearnDash

• You must protect student data using HTTPS, access controls, and breach prevention measures.

Cookies should be controlled, and data collection should be limited to what is truly necessary, such as avoiding collecting addresses unless required (e.g. for VAT calculation).

If the LearnDash course platform targets children, the rules are stricter and may require parental consent. You can read more about the Age Appropriate Design Code.

Database organisation

• The ICO expects platforms to store only necessary data, use encryption, access controls, and protection against breaches.

This is why, when developing a LearnDash website, I align protection, design, accessibility, and security. More importantly, it is essential to understand who your students are and what data will be collected.

Mistakes to avoid in your LearnDash course

• Capturing emails and immediately adding them to a marketing list without consent;
• Not having a clear and updated privacy policy;
• Using Google Analytics before the user accepts consent conditions;
• Not allowing account deletion;
• Sharing data with tools without informing users.

If you are migrating from another course platform to LearnDash or a custom solution, it is important to understand how the current platform handles student data before migrating, and to inform users and request consent for data transfer.

Frequently Asked Questions

What fines can I face if my LearnDash course does not comply with UK GDPR?

In 2026, the ICO has become more active in enforcement, so compliance is essential. Fines under the UK GDPR (and DUA context) vary by severity:

• Level 1 – Administrative infringements: failures in record-keeping, breach notifications, or lack of a DPO.
  Fine: up to £8.7 million or 2% of global annual turnover (whichever is higher).
• Level 2 – Serious infringements: violation of core processing principles, lack of legal basis (invalid consent), or failure to respect data subject rights.
  Fine: up to £17.5 million or 4% of global annual turnover (whichever is higher).

Of course, the ICO does not automatically apply the maximum fine. They assess factors such as the nature and duration of the breach, intent, type of data involved, and other criteria.

What is the best setup to ensure my LearnDash site complies with UK GDPR?

• Prior cookie blocking: tracking scripts should only load after user consent;
• Explicit marketing consent (no pre-ticked boxes);
• Use plugins such as Complianz or CookieYes, configured for UK jurisdiction;
• Configure LearnDash registration forms to collect only essential data;
• Student dashboard with clear data, editing options, and account deletion;
• Hosting: preferably within the UK;
• 2FA (two-factor authentication) strongly recommended for admins and instructors;
• Database encryption;
• Custom privacy notice (avoid generic templates);
• DPA: if hiring a marketing agency, ensure a signed agreement detailing data processing;
• ROPA (Record of Processing Activities): maintain a simple record of what data you collect, where it is stored, why it is needed, and when it will be deleted.

These optimisations can help protect your LearnDash course from fines of up to £17.5 million.

If you are looking for a LearnDash developer focused on the UK, feel free to contact me.

Save this article, as whenever I find updates regarding the DUA, UK GDPR, or data protection laws, I will update it here. Also check other articles to better understand how to develop your LearnDash course with strong acceptance in the United Kingdom.