GliaNet Alliance Submits to UK’s Call for
Evidence on Data Intermediaries

May 21, 2025 

On May 12, 2025, GliaNet Alliance submitted a formal response to the UK Department for Science, Innovation & Technology’s (DSIT) open call for evidence on Data Intermediaries.

The consultation explored 11 key questions about how individuals can exercise their data rights, how third parties might assist them, and what regulatory frameworks are needed to support a trustworthy ecosystem of digital intermediaries.

In our submission, we emphasized a core concern: the dominant model of treating personal data as a commodity—through extraction and surveillance—has failed to produce trusted or inclusive markets. Today’s platform-driven environment prioritizes monetization over user agency. While helping individuals protect or monetize their data is important, it’s not enough.

We proposed a new approach—centered on Net Fiduciaries™: intermediaries that operate under legal and ethical duties of care, loyalty, and good faith. These actors do more than process data. They serve as trusted digital agents who help people make informed decisions, exercise their rights, and navigate an increasingly AI-mediated web. Key recommendations from our submission include:

• Legal recognition of third-party delegation of all data subject rights under UK GDPR.

• Creation of a statutory category for Net Fiduciaries™, with enforceable fiduciary duties.

• Open, interoperable standards for consent, portability, and AI-to-AI interaction.

• Inclusive governance design, emphasizing accessibility, co-creation, and multilingual tools.

We urged DSIT to broaden its definition of intermediaries to include not just data portability or monetization services, but also actors involved in algorithmic decision support, AI agents, and edge-based personal technologies. These use cases increasingly influence everyday decisions—from health to finance to reputation—demanding a new layer of ethical accountability.

As platform-based AI systems and LLMs begin making decisions for users—not just about them—the case for fiduciary governance becomes urgent. Trust must be embedded at the infrastructure level.

GliaNet’s community of practice is already working to make this real—developing governance frameworks, model agreements, technical standards, and pilot designs to support a new generation of trustworthy intermediaries.

This submission reflects our broader mission: rebuilding digital trust by equipping Net Fiduciaries™ and AI agents with open source governance frameworks rooted in care and loyalty. We believe vibrant, inclusive digital markets can only emerge when trust is a core design principle—not an afterthought.

We welcome continued dialogue with UK policymakers, regulators, and innovators advancing ethical infrastructure in the digital age.

Read our full submission, here.