In an email to Memorial University President Janet Morrison on August 26, 2025, then Associate Vice-President (Harlow Campus and Global Partnerships) Jingjing Xu stated that any processing of her personal data “must comply with the UK GDPR and Data Protection Act 2018,” and that any disputes concerning the contract fall “exclusively within the jurisdiction of the courts of England and Wales.”
In a follow-up email to President Morrison on September 2, 2025, Xu stated that, as Director and Chair of MUN UK Ltd, she would be aware that the company is subject to the laws of England and Wales and the UK GDPR.
Xu wrote that, under UK law, directors “owe a personal duty to ensure that the companies they oversee comply with all applicable legal obligations.” She said, “under the UK GDPR, with the consent, connivance, or neglect of a director, that director may also be personally liable, including exposure to fines and civil remedies.”
“The risk of such liability is well established, and directors have been held accountable where oversight has failed.”
Xu warned that the potential consequences of violating the UK GDPR are “extremely serious,” and that “organizations found in breach can face administrative fines of up to £17.5 million or 4% of total worldwide annual turnover (whichever is higher).
She also stated that the UK’s Information Commissioner’s Office had repeatedly issued multi-million-pound fines in cases of “unlawful processing or disclosure of personal information.”
“The reputation and legal consequences for both the company and its directors can be profound.”
Addressing President Morrison directly, Xu stated: “In your capacity as Chair of MUN UK Ltd, and as President and Vice-Chancellor of Memorial University, you bear responsibility for ensuring that MUN UK Ltd complies fully with its legal obligations under UK law.”
However, in a report issued on March 20, 2025, the Information and Privacy Commissioner Newfoundland and Labrador determined that UK law does not apply to limit disclosure of the record in Newfoundland and Labrador.
On April 3, 2025, then-president Neil Bose advised the Information and Privacy Commissioner Kerry Hatfield that Memorial would be applying to the Supreme Court for a declaration that it does not have to comply with the recommendations set out in the report based on it being a breach of the law in the UK.
In an investigation report issued on April 13, 2025, by Chantelle MacDonald Newhook, Bose was found to be in violation of Memorial’s Conflict of Interest Policy and its related procedures for appointing his personal friend and co-author, Jingjing Xu, to the position of Associate Vice-President (Harlow Campus and Global Partnerships).
Memorial President Janet Morrison later decided to discontinue the court application, and Xu’s employment contract was subsequently released.
View Xu’s emails below:
Matt Barter is a graduate of the Humanities and Social Sciences Faculty at Memorial University of Newfoundland, holding a degree in Political Science with a minor in Sociology. He enjoys reading thought-provoking articles, taking walks in nature, and volunteering in the community.
Leave a Reply