PD Almanac catalogue

Catalogue of data subject categories

Categories of data subjects in five groups, the basis of the list for most organisations

  • Current as of 15.11.2025
  • Entries: 47
Contents5 sections, 47 entries

The catalogue consists of categories of data subjects grouped into 5 groups and applies to most organisations. The list of subject categories given is not exhaustive and must be adapted or supplemented to reflect the specifics of an individual organisation's activities and their regulation.

Applicants and related persons

1. applicants for a vacant position with the Operator - individuals applying for a vacant position with the Operator and wishing to conclude an employment contract with it (except applicants who are already current employees of the Operator); such persons may also receive, and accept or decline, the Operator's offer of the vacant position

2. referrers and referees of applicants for a vacant position with the Operator - referrers who provide initial information on an applicant for a vacant position with the Operator, and referees who confirm the business qualities of such an applicant

3. family members and other relatives of applicants for a vacant position with the Operator - family members, other relatives, in-laws and acquaintances of applicants for a vacant position with the Operator

4. persons of personal interest to applicants for a vacant position with the Operator - individuals with whom the personal interest of applicants for a vacant position with the Operator is connected

5. members of the Operator's talent pool - individuals who are or are not current employees of the Operator and are in the Operator's talent pool (external talent pool)

Staff, owners and related persons

6. employees of the Operator - Russian or foreign nationals in an employment relationship with the Operator

7. former employees of the Operator - Russian or foreign nationals previously in an employment relationship with the Operator

8. non-staff personnel involved in the Operator's activities - personnel of the Operator's counterparties or independent individual counterparties of the Operator who take part (have previously taken part) in the Operator's activities

9. non-staff personnel performing a job function for the Operator - personnel of the Operator's counterparties who temporarily perform (have previously performed) a job function in the interests, under the management and control of the Operator1)

10. interns and placement students of the Operator - individuals undergoing (or who have undergone) professional training with the Operator as an internship or work placement (production or educational)

11. family members and other relatives of the Operator's employees - adult and minor family members, other relatives and in-laws, wards and dependants of current and former employees of the Operator

12. contact persons of the Operator's employees - individuals named by current and former employees of the Operator as contacts in unforeseen circumstances

13. beneficiaries of the Operator's employees - individuals designated as beneficiaries under the relevant insurance contracts of current and former employees of the Operator

14. recipients of payments connected with the Operator's employees - individuals receiving maintenance (alimony) from current and former employees of the Operator, and individuals (family members, other relatives, dependants, funeral organisers, heirs by law or designated by the employee) receiving compensation, allowances, financial assistance and other payments in connection with the death of an employee of the Operator

15. persons of personal interest to the Operator's employees - individuals with whom the personal interest of current and former employees of the Operator is connected

16. persons accompanying the Operator's employees on trips - adult and minor individuals accompanying the Operator's employees on trips of various kinds

17. representatives (agents) of the Operator - individuals authorised, or previously authorised, to represent the Operator's interests (a representative acting on behalf of and in the interests of the Operator)

18. management personnel of the Operator not in an employment relationship with it - members of the management and supervisory bodies of the Operator, and of legal entities affiliated with the Operator (members of the Operator's group of persons), who are not in an employment relationship with the Operator

19. owners of the Operator - individuals - individuals who are owners (participants, shareholders) or beneficial owners of the Operator

20. personnel of the Operator's owners and affiliates - individuals (employees, representatives) connected with legal entities that are owners (participants, shareholders), beneficial owners and other persons affiliated with the Operator (other persons in the Operator's group)

21. advocates as participants of the Operator - advocates who intend to become, are or were participants in a legal-profession entity (the Operator)

Counterparties and related persons

22. personnel of the Operator's counterparties (clients, suppliers, contractors, agents, partners) - individuals (employees, representatives) connected with prospective, current or former counterparties and sub-counterparties of the Operator (legal entities and individual entrepreneurs) who are clients, suppliers, contractors, agents or partners of the Operator

23. clients of the Operator's counterparties (clients, suppliers, contractors, agents, partners) - individuals who are prospective, current or former clients (buyers, customers, subscribers, users, patients, insured persons, etc.) of prospective, current or former counterparties and sub-counterparties of the Operator

24. the Operator's counterparties - individuals (clients, suppliers, contractors, agents, partners) - individuals, individual entrepreneurs and self-employed persons who are prospective, current or former counterparties and sub-counterparties of the Operator and are clients, suppliers, contractors, agents, partners or consumers

25. owners and affiliates of the Operator's counterparties [and of specialised financial companies whose sole executive body powers are exercised by the Operator] - individuals (owners (participants, shareholders), beneficial owners and other affiliates) connected with prospective, current or former counterparties and sub-counterparties of the Operator [and specialised financial companies whose sole executive body powers are exercised by the Operator]

26. personnel of the owners and affiliates of the Operator's counterparties [and of specialised financial companies whose sole executive body powers are exercised by the Operator] - individuals (employees, representatives) connected with legal entities that are owners (participants, shareholders), beneficial owners and other persons affiliated with the Operator's counterparties [and with specialised financial companies whose sole executive body powers are exercised by the Operator,] (other persons in the group of the Operator's counterparties)

27. persons connected with key personnel of the Operator's counterparties - individuals (family members, other relatives, in-laws or cohabitants (a partner living together without marriage registration)) connected with the key personnel of prospective, current or former counterparties of the Operator

28. principals of the Operator - individuals who intend to entrust, or entrust or have previously entrusted, the Operator (agent) with performing legally significant acts in their name and at their expense

29. beneficiaries and insured persons - individuals who are not a party to the contract (the policyholder) but in whose favour an insurance contract is concluded, or who are entitled to receive an insurance payment as successors or heirs

30. counterparties of specialised financial companies whose sole executive body powers are exercised by the Operator - individuals (including, but not limited to, purchasers of securities, bondholders, agents)

Interacting persons

31. personnel of authorised bodies and organisations - individuals (officials, employees, staff members, representatives) connected with authorised bodies and organisations that are not counterparties of the Operator and with which the Operator interacts or intends to interact

32. users/visitors (unregistered and registered) of the Operator's information resources - users/visitors (unregistered and registered) of websites on the Internet and (or) mobile applications operating in the Operator's interests

33. recipients of messages from the Operator - individuals who receive informational/service, marketing/advertising and (or) other messages from the Operator

34. senders of messages to the Operator - individuals (including employees and representatives of legal entities) who send messages and (or) information materials of any kind to the Operator

35. persons named in messages to the Operator - individuals whose details are contained in messages and (or) information materials of any kind sent to the Operator

36. participants in the Operator's events - individuals (including employees and representatives of legal entities) taking part in the Operator's events (including contests, games, promotions) and research

37. visitors to the Operator's real estate - other individuals visiting the Operator's real estate

38. participants in and witnesses of a road traffic accident involving the Operator's vehicle - participants in and witnesses of a road traffic accident involving a vehicle owned by the Operator (used in the Operator's interests)

39. participants in court proceedings and enforcement proceedings in which the Operator is involved - individuals (including employees and representatives of legal entities) taking part in court proceedings and enforcement proceedings in which the Operator is involved

Other categories of data subjects

40. healthcare professionals - doctors and other medical staff, experts (including candidates of sciences or scientists) and other opinion leaders, and members of initiative (public) groups in the field of healthcare

41. government officials - officials and employees of a state body or organisation, a political party, party workers or candidates of a political party, or an international organisation

42. patients - individuals receiving medical care, under medical observation and/or treatment for any disease, pathological condition or other impairment of health and vital functions, and also using medical services regardless of whether they have a disease

43. reporters of pharmacovigilance information - individuals who disseminate information on adverse events, quality complaints and special situations

44. ethics committee members - individuals who are members of an independent ethics committee (ethics council, ethics commission)

45. consignors and consignees - individuals connected with the Operator's counterparties (consignors and consignees) with whom the Operator interacts in the interests of its counterparties

46. consumers - individuals who intend to order or purchase, or who order, purchase or use goods (works, services) solely for personal, family, household and other needs unrelated to business activity

47. users of the Operator's products - individuals connected with the Operator's counterparties with whom the Operator interacts in the course of selling and servicing the Operator's own products

1) This category applies where outstaffing services are lawfully provided to the Operator under Chapter 53.1 of the Labour Code.
Contents