The NRS figure reveals that that the of 130,000 in the period July 2009 to June 2010, a fall of 39% on the previous year.
Tim Blott, managing director for Newsquest’s Scottish titles, said: "I am going to complain strongly about the process. I can’t see the correlation between our circulation and the readership figure by NRS."
Blott said he had spoken to the NRS in the past over concerns over the data it has produced, even when it had appeared to benefit the title.
According to the latest ABCs data, the circulation of the Herald dropped 6.8% year on year in July, to 52,182.
While the Audit Bureau of Circulations figures reveal the number of copies distributed, the NRS uses a survey of a panel of 36,000 people to calculate how many readers a publication has.
Blott is also to complain to the NRS that he had not seen the data, until Media Week asked him to comment on it.
Newsquest, which publishes around 300 regional titles in the UK, is not considering pulling out the NRS at this stage.
At least one publisher has previously voiced concerns that the NRS sample size is too small to produce valid results.
The NRS attracted – now closed – which disputed its methodology and threatened to quit the survey back in 2008.
Last year, the NRS undertook a rebrand under chief executive Mike Ironside as it looked to reflect the importance of NRS survey data and its place in the media measurement space.
The NRS said it did not comment on individual cases.
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