Data held within the Manuscripts & Special Collections archives
For the purposes of compliance with the General Data Protection Regulation (GDPR) Manuscripts & Special Collections lawful basis for processing personal data is ‘archiving in the public interest’. This means that under Part 6 27 (1) of the Data Protection Act (DPA) 2018 the GDPR provisions do not apply to personal data processed for:
(a) scientific or historical research purposes, or
(b) statistical purposes.
We provide free and open access to our collections and meet the standards expected of archive repositories in the UK. Data held within the archives is still subject to the UK safeguards contained in section 19 of the Data Protection Act 2018.
Processing for archiving in the public interest will not meet the safeguard requirements if it is: ‘likely to cause substantial damage or substantial distress to a ‘data subject’ or is ‘carried out for the purposes of measures or decisions with respect to a particular data subject, unless the purposes for which the processing is necessary include the purposes of approved medical research’
GDPR and research
Under Article 89 (3) of the GDPR personal data processed for archiving purposes in the public interest is permitted subject to certain safeguards. Those safeguards shall ensure that “technical and organisational measures are in place particularly to ensure respect for the principle of data minimisation”.
This means that data should be pseudonymised or anonymised if it relates to a living person, contains personal or sensitive information and that person could be identifiable from any research. This is particularly important if research is intended for publication.
We will make every effort to notify you of any circumstances where you are likely to encounter such data but you are responsible for the processing of such data.