This notice explains how King’s College London processes personal data in connection with TOT Insights research on public officials and governance in Russian-occupied Ukrainian territories. Click the bar below to read the full notice.
Temporarily Occupied Territories (TOT) Insight Hub
Processing of personal data relating to individuals holding public roles in Russian occupation governance.
King’s College London (“King’s”) is the data controller for the research described below. This notice explains how the TOT Insight Hub, a research project of the Ukraine and Russia Programme at the Centre for Statecraft and National Security, processes personal data about individuals who hold public roles in the Russian occupation administration of Ukrainian territory.
We process public-role information - names, official positions, appointment dates, and documented public decisions and statements - of individuals exercising governance functions in occupied territories. This information is drawn from publicly available sources, including official Russian and occupation-administration publications, government records, and court decisions. We do not publish personal data beyond the public role unless a specific, documented accountability justification applies.
The research documents the legal, administrative, economic, and educational mechanisms of Russian occupation governance, in the public interest and for academic research. Our lawful basis is legitimate interests (Article 6(1)(f) UK GDPR). Where the data reveals political opinions, we rely on the research-purposes condition (Article 9(2)(j) UK GDPR and Schedule 1, Part 1 DPA 2018), with the safeguards required by Article 89 UK GDPR.
Contacting each individual would involve disproportionate effort and would risk prejudicing the research. We therefore rely on the research provisions exemption from the duty to notify individuals directly (Article 14 UK GDPR), and meet our transparency obligation by publishing this notice.
Public-role information is retained for the duration of the project and for as long as required for research and accountability purposes, in line with King’s Records Retention Schedule.
You have rights over your personal data, including rights of access, rectification, objection, and (in some circumstances) erasure. Some of these rights may be limited where they would prevent or seriously impair the research purpose. To exercise a right or raise a concern, contact the Principal Investigator, Dr Jade McGlynn ([email protected]), or King’s Information Compliance team ([email protected]). King’s Data Protection Officer is contactable at [email protected]. You also have the right to complain to the Information Commissioner’s Office (ico.org.uk).
Last updated: 1 June 2026