Ethics in the inGOV project
The inGOV project belongs to citizen-centric ones which require public participation and stakeholders’ engagement, so for this reason ethics considerations constitute high priority.
The inGOV project belongs to citizen-centric ones which require public participation and stakeholders’ engagement, so for this reason ethics considerations constitute high priority. All consortium partners have carried out all the actions in accordance with the ethical principles, including the highest standards of research integrity as set out in the European Code of Conduct for Research Integrity, avoiding fabrication, falsification, plagiarism or another research misconduct. What is more, all activities have been conducted in compliance with the applicable international, EU and national laws, respecting the protection of personal data and finally after having taken into consideration the ethics guidelines for Trustworthy AI published on the 8th of April 2019 by the High-Level Expert Group on AI. Furthermore, it should be highlighted that all the ethical issues have been handled among the Ethics Manager and the Ethics Committees’ or DPOs of the inGOV consortium partners, so as to safeguard compliance with the EU and national frameworks, satisfying the project requirements and mainly transparency.
To be more specific, the ethical monitoring of the project was aligned to each protocol and all procedures were organized per WP, covering three different workstreams of the project. Based on the ethics management overall strategy that was developed to all WPs that were engaged with human participation, meaning WP1, WP2 and WP4, each partner was encouraged to obtain either an Ethics Approval by the relevant Ethics Committee or a DPO Opinion by its DPO, moving at a national level. For additional safety, in case of WP1 the WP Leader has obtained an Ethics Approval by the Ethics Committee, acting as the “umbrella” for all the other engaged partners.
Special attention was given to consent procedures, always having taken into consideration the voluntariness of participation, as a choice under free will, and the data processing in language and terms intelligible to participants, showing adherence to a wide spectrum of moral values and fundamental rights. Particularly, great emphasis was placed on respect of human dignity and autonomy, justice and transparency, privacy and confidentiality while the right to be informed/of access/to erasure/to object/to data portability/to rectification/to restrict processing were acknowledged to participants. All of the above mentioned were applied having always in mind the social responsibility and common good orientation, with special focus on beneficence/maximize benefit and on non-maleficence/minimize risk. Non-stigmatization and non-discrimination principles were of crucial significance to all engaged participants, especially in case of vulnerable ones, where no sensitive data in relevance to their disability were gathered.
The probability of incidental findings in the course of the inGOV research was relatively low. Also, all technical and security measures were in place, focusing on the central storage of the research documents, including personal data, till five years after the end of the project. What is more, all organisational measures were applied, emphasizing the assignment of the DPOs and the role of the Ethics Manager along with the WP leader in order to mitigate measures in case of any non-compliant actions within a specific timely manner. Additionally, full compliance with the ethical and legal requirements was ensured by the appointment of both the Ethics Manager, internally, and the Ethics Advisor, externally.
Last but not least, pseudonymization techniques have taken place, meaning that only anonymized data were transferred to the consortium partners and all data requested were adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed in accordance with Article 5 of GDPR, based on data minimization principle. So, the evaluation of ethics risks with regards to the data processing was low and no Data Protection Impact Assessment was necessary, according to Article 35 of the GDPR 2016/679.