B. I intend to archive my research data, should I anonymise any personal data before archiving?

Law
B. I intend to archive my research data, should I anonymise any personal data before archiving?

ScanSolve AI Answer

A. You want to archive research data containing personal data from survey respondents. Personal data must be protected according to data security requirements (Art. 32 GDPR).

You should encrypt it before archiving to prevent unauthorized access.

Yes.

B. Personal data is information relating to an identified or identifiable natural person (Art. 4(1) GDPR).

Survey data from respondents is personal data.

Anonymised data is not personal data if individuals cannot be re-identified.

Pseudonymised data is still personal data (can be re-identified with additional information).

Survey data: yes; anonymised: no; pseudonymised: yes.

C. Data subject is a natural person to whom the personal data relates (Art. 4(1) GDPR).

Children are data subjects if the data relates to them.

Deceased persons' data is not personal data (must relate to living persons).

Survey data relates to living respondents, so they are data subjects.

Data subjects are living natural persons, including children.

D. Data subject: natural person the data relates to.

Sensitive personal data (special categories, Art. 9 GDPR): data revealing racial/ethnic origin, political opinions, religious beliefs, health, biometrics, etc.

Difference: data subject is the person; sensitive personal data is a type of data requiring extra protection.

Data subject: the person; sensitive data: specific types of data.

E. Anonymised data, if truly irreversible and no re-identification possible, is not personal data (Recital 26 GDPR).

No.

F. If you determine the purposes and means of processing your research data, you are the data controller (Art. 4(7) GDPR).

For data protection purposes, yes, you are the controller for your research.

Yes.

G. Data controller: the natural or legal person which determines the purposes and means of processing (Art. 4(7)).

Joint controllers: two or more controllers who determine purposes and means jointly (Art. 26).

Controller: decides purposes/means; joint: together.

H. In a collaborative research project, the institution(s) determining the purposes and means of processing is/are the controller(s).

If you process on their behalf, you are the processor.

The leading institution or all jointly.

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