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What is research related processing?

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Latest updates - 27 February 2026

27 February 2026 - this draft guidance was published.

At a glance

  • The RAS provisions refer to four types of research-related purposes for processing personal information. They are:
      • archiving purposes in the public interest;
      • scientific research purposes;
      • historical research purposes; and
      • statistical purposes.
  • To rely on the RAS provisions, you must demonstrate that your processing is necessary for one of these research-related purposes.
  • We’ve developed a set of criteria to help you understand the scope of each of these purposes. 

In detail

What is processing for research-related purposes?

Process for research-related purposes is processing you carry out for any of the following purposes:

  • archiving purposes in the public interest;
  • scientific research purposes;
  • historical research purposes; or
  • statistical purposes.

You must be able to demonstrate that your processing falls within the scope of one of the research-related purposes for processing.

To do this, you should be able to demonstrate that your processing meets the criteria set out below for one of the types of research-related purposes for processing.

What is archiving in the public interest?

Archiving in the public interest ensures the permanent preservation and usability of records of enduring value for general public interest.

Organisations archive information to maintain and provide long-term access to it for public use. However, archives often contain the personal information of living identifiable people.

Data protection law recognises that there is a public interest in permanently preserving some records containing personal information. Doing this offers a long-term benefit to society.  

Archiving in the public interest is about managing and preserving records with potentially enduring public value. Organisations must not use the provisions for archiving to:

  • justify indefinitely keeping records with no potential public value; or 
  • to keep information without active and ongoing management.

Some bodies with specific legal obligations, such as the National Archives, National Records of Scotland and the Public Record Office of Northern Ireland, carry out archiving in the public interest. Public bodies, such as local authorities, may also have a public task set out in law to maintain records and archives. 

However, many organisations that archive in the public interest don’t have to do so by law. Private or third sector organisations may also carry out archiving in the public interest.

Archiving in the public interest is distinct from keeping records over long periods for business or legal purposes. Organisations sometimes use the term archiving to mean sending records to offsite storage or moving data from a live system. However, for the purposes of the RAS provisions, you’re not archiving in the public interest if:

  • you’re keeping records solely for current business or legal purposes; and 
  • those records have no confirmed or potential enduring public value.

The following table gives examples that we would consider archiving in the public interest, and examples that we wouldn’t.

Archiving in the public interest Not archiving in the public interest
  • Enabling research and investigations.
  • Ensuring long-term accountability.
  • Preserving personal, community and corporate identities, memories and histories.
  • Helping to establish and maintain rights, obligations and precedents.
  • Securing records for future educational, academic or development purposes. 
  • Maintaining records for current business needs or legal purposes.
  • Storing records for a specified limited time. 
  • Keeping records with no confirmed or potential enduring value to society.

 

What is scientific research?

Article 4(2) of the UK GDPR provides detail about the meaning of ‘scientific research’.

It states that references in data protection law to scientific research refer to “processing for the purposes of any research that can reasonably be described as scientific, whether publicly or privately funded and whether carried out as a commercial or non-commercial activity”.

Article 4(3) states that these purposes, as long as you can reasonably describe them as scientific, include:

  • technological development or demonstration;
  • fundamental research;
  • applied research; and
  • public health studies conducted in the public interest.

The scope of scientific research is broad. It includes research carried out in traditional academic settings. It also includes all areas of academic research such as the social sciences, humanities and the arts. 

Scientific research aims to:

  • advance the state of the art in a given field;
  • provide innovative solutions to problems;
  • generate new understandings or insights that add to human knowledge in a particular area; 
  • support education; or
  • produce general findings for researchers to test and try to repeat. 

Scientific research includes:

  • fundamental or basic research – experimental or theoretical work done primarily to gain new knowledge of how things work, without any particular application or use in mind;
  • applied research – original investigation made to gain new knowledge, mainly for a specific, practical aim; and
  • experimental development – systematic work that draws on research and practical experience to gain knowledge which produces new products or processes, or improves existing products or processes.

This definition of research includes activities such as:

  • carrying out research that informs policy and practice but doesn’t necessarily result in published findings; 
  • applying and explaining scientific research; 
  • demonstrating the replication or reproducibility of research;
  • research on real-world evidence; and
  • secondary use of clinical trials data.

Scientific research can be done by:

  • public sector bodies;
  • commercial organisations;
  • charitable organisations;
  • independent researchers. 

If you’re carrying out scientific research, you may rely on the RAS provisions in your processing. To help you determine whether your processing falls within the scope of scientific research, we’ve developed a set of four criteria that your processing should meet:

  • Scientific objective;
  • Scientific method;
  • Uncertainty; and
  • Transferability.

We explain the meaning of each of these criteria. We also provide a list of indicative evidence you could use to demonstrate that your processing meets the criteria.

We also provide a list of exclusionary evidence. This is evidence that your processing does not meet the criteria, and therefore is not likely to meet the definition of scientific research.

 

Scientific objective

To qualify as scientific research, your work should aim to make a meaningful improvement in science or technology. This improvement should benefit the entire field, not just the organisation doing the research. In the area of public health, you must also ensure that the research serves the public interest.

This does not mean the research has to be successful in this objective. What matters is that you carry out research with a genuine aim of making a meaningful improvement in science or technology. This counts even if the research ultimately fails to make this improvement. 

Indicative evidence Exclusionary evidence
  • The people doing the work are skilled and knowledgeable in the field.
  • The work is carried out by, or in partnership with, a recognised research organisations such as a university.
  • The work uses competitive funding received through peer reviewed grants.
  • The research causes substantial harm or substantial distress to the people whose information it uses.
  • The research involves using personal information to make decisions about the people whose information it is (except approved medical research, where this is not an exclusion).
  • A skilled professional could easily achieve the improvement being pursued using publicly available information.
  • The work is simply copying, tweaking, or reverse-engineering an existing technology.

Scientific method

For your work to qualify as scientific research, you should make sure it’s well planned, documented, and systematically carried out. It should follow ethical standards for the field, and be recognisable as scientific by someone with expertise in that area. This includes systematic methods in the humanities and social sciences.

Indicative evidence Exclusionary evidence
  • The work uses or adapts recognised research methods. 
  • You’re following ethical guidelines or have approval from an ethics committee. 
  • You keep records of how you did the research and what the results were. 
  • The work only involves support activities, such as finance, transport, human resources, or security, rather than research itself.
  • You carry out the work without appropriate safeguards in place to protect people’s rights and freedoms.

 

Uncertainty

To qualify as scientific research, you should aim to solve meaningful scientific or technical problems where the outcome isn’t obvious in advance, even to experts. 

Indicative evidence Exclusionary evidence
  • You can show that the result wasn’t guaranteed, even with enough resources.
  • The researchers have freedom to explore and make decisions. 
  • The work uses creative approaches to solve problems.
  • You recognise that the problem is still open or debated in existing research. 

 
  • The only uncertainty is commercial, such as market demand for a product or service, rather than scientific or technological.
  • The only uncertainty is regulatory or legal, unless it’s genuinely unclear whether the rules can be followed from a scientific or technical standpoint. 
  • The work merely customises existing technology, unless it’s genuinely unclear whether the customisation is even possible. 
  • The work involves building a prototype, unless there is real uncertainty about how to do it.

Transferability

For your work to qualify as scientific research, you should ensure that it produces new knowledge that you could share or others could use. This does not mean you must publish it or make it public, but it must sharing it must be possible. 

Indicative evidence Exclusionary evidence
  • You document how you did the research.
  • You publish or present the method to others in the field. 
  • You apply for intellectual property protection, such as a patent. 
  • You share code or have the work used in further research. 

 
  • The researchers keep the resulting knowledge only in their minds without recording it. 

Example

A technology company provides biometric identity verification technology to its business clients. The business clients use the company’s services to verify the identities of their customers. To provide these services to its business clients, the company processes personal information in the form of the customers’ faces. The business clients provide images of their customers’ faces. The technology company compares these images with the images on the customers’ IDs. It uses its verification technology to determine whether each customer’s face matches their ID and whether their ID is genuine.

The company becomes aware that its facial recognition technology is less accurate in identifying matches for certain groups of people. This is because of the broad diversity of facial characteristics across the world. The company decides to perform research into how its algorithms can lessen this bias and treat everyone fairly and inclusively.

The company carries out this research with appropriate safeguards in place for people’s rights and freedoms. It only uses the outcomes of this research to train the algorithm to make better decisions in future. 

We can regard the processing of personal information for the purposes of investigating weaknesses in the algorithm to improve its effectiveness as processing for scientific research purposes.

Relevant provisions in the legislation

Further reading

What is historical research?

Data protection law doesn’t give a lot of detail about the meaning of historical research. Article 4(4) of the UK GDPR states that it includes processing done for genealogical research purposes.

A lot of historical research relates to people and events so far in the past that it doesn’t involve processing personal information at all. Data protection law only applies to information about identifiable living people. Information about people who have died is not personal data, and is therefore not subject to data protection law.

However, historical research may sometimes involve gathering personal information about living people. In these cases, data protection law applies, and you may sometimes need to rely on the RAS provisions.

While the methods and approaches of historical research are different from those of scientific research, the standards of ethics and research integrity are similar. If you are carrying out historical research and want to use the RAS provisions, you should ensure you meet the criteria given above and can demonstrate this.

Example

A university starts a research project to investigate the experiences of people who move to the UK in the 1950s and 1960s. The researchers also want to compare the experiences of people from different ethnic groups.

The processing of this personal information is for historical research purposes.

What is processing for statistical purposes?

Processing for statistical purposes is processing done mainly to carry out statistical surveys or produce statistical results. However, not all processing that creates statistical results counts as processing for statistical purposes. 

Processing for statistical purposes refers only to activities where statistical outputs are the main aim or purpose. You may then use these statistical results for further purposes, including scientific research.

Public authorities and bodies obliged by law to produce and disseminate official statistics, such as the Office for National Statistics, may conduct processing for statistical purposes. But the category also covers a much broader range of uses than this. Private or third sector organisations may also carry out this processing. It includes any processing operation, including the collection of personal information, necessary for statistical surveys or the production of statistical results.

For processing to be recognised as being for statistical purposes, the organisation doing the processing must ensure that:

  • the results of the processing are anonymous, aggregate data, and so no longer contain personal information; and
  • you don’t use the personal information processed, or the information that results from that processing, in support of measures or decisions about the people whose information it is. 

If you hold other information that you could combine with the results to re-identify people, the results only count as pseudonymised, rather than anonymised. This means that your results still contain personal information, so your processing doesn’t count as being for statistical purposes. 

Further reading – ICO guidance