POPD – Requirement No. 4

This deliverable addresses the comments documented in the Ethics Summary Report after the successful proposal evaluation. The post-grant requirements for this deliverable are related to the Protection of Personal Data in the inGOV Project.

Executive Summary

This deliverable, under WP8 Ethics requirements, addresses the comments documented in the Ethics Summary Report after the successful proposal evaluation. The post-grant requirements for this deliverable are related to the Protection of Personal Data in the inGOV Project.

More specifically the requirements are the following:

  • The beneficiary must evaluate the ethics risks related to the data processing activities of the project. This also includes an opinion if the data protection impact assessment should be conducted under the Article.35 of the General Data Protection Regulation 2016/679. The risk evaluation and the opinion must be submitted as part of a deliverable.
  • The informed consent procedures that will be implemented for the participation of humans in the pilots and in regard to the data processing must be submitted as part of a deliverable).
  • Templates of the informed consent forms and information sheets covering the voluntary participation (humans) and the data processing (in language and terms intelligible to the participants) must be submitted as part of a deliverable.
  • A description of the technical and organizational measures that will be implemented to safeguard the rights and freedoms of the data subjects/research participants must be submitted as part of a deliverable).
  • Justification for the processing of sensitive personal data must be submitted as part of a deliverable. The beneficiary must explain how all of the data they intend to process is relevant and limited to the purposes of the research project (in accordance with the “data minimization” principle). This must be submitted as part of a deliverable.
  • Description of the anonymization/pseudonymization techniques that will be implemented must be submitted as part of a deliverable.
  • A description of the security measures that will be implemented to prevent unauthorized access to personal data or the equipment used for processing must be submitted as part of a deliverable.
  • In case of further processing of any previously collected personal data, an explicit confirmation that the beneficiary has lawful basis for the data processing and that the appropriate technical and organizational measures are in place to safeguard the rights of the data subjects must be submitted as part of a deliverable.

To this end D8.2:

  • Similarly to D8.1, maps all the cases across the inGOV WPs, where ethical monitoring is necessary, taking into consideration the Protection of Personal Data; these cases are related both to human participants in pilots, as identified in Protocols 1-3, and to any other human participant, involved in stakeholders’ activities.
  • Identifies the procedures that should be carried out, safeguarding the GDPR compliance.

However, since by the time this deliverable should be submitted [M06], the inGOV consortium did not have the level of detail needed for the overall ethical monitoring of the project, D8.2 reports on the processes that are already in place for Protocol 1 and provides a high level presentation of Protocols 2 and 3; it leaves the detailed description of the ethical monitoring and the provision of all the respective documentation of Protocols 2 and 3 to be submitted in M18, namely in the updated version of this Deliverable, under the following rationale:

  • by M18 the project itself will have progressed to a certain level, enabling the inGOV consortium to have a better overview of both WP3 and WP4;
  • as such by that period the related Protocols 2 and 3 could be described and documented in detail.

Finally, with regards to the ethical monitoring of other WPs, related to the Protection of Personal Data in stakeholders’ activities, a high-level description is provided in the current report, along with a reference to the Deliverables, where all the relevant documentation will be finally reported.

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