Organisations, particularly those in the life sciences sector, should take note of the ICO’s draft updates to its guidance on the Research, Archiving and Statistics (RAS) provisions(1) (the Guidance) under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). The RAS provisions themselves are not new. What is new is the way the Guidance responds to amendments introduced by the Data (Use and Access) Act 2025 (DUA Act 2025) and reflects the ICO’s updated expectations on how personal data can be used for research purposes under UK law.

The DUA Act 2025 amends the UK GDPR to clarify and, in some respects, broaden the framework for the use of personal data in scientific research and other research-related purposes. The RAS provisions cover four types of research-related purposes: archiving in the public interest; scientific research; historical research; and statistical purposes.