Study on the EC Open Research Data Pilot and Personal Data Rules

"Summary:

• The Open Research Data Pilot aims at making research data generated by projects freely available and reusable on Open Access basis.
• If such research data include personal data, data protection rules are applicable to the use in the Open Research Data Pilot.
• The use of personal data within the Open Research Data Pilot is at odds with leading data protection principles.
• The Open Access use of personal data cannot be legitimised by a research exception or the consent of the data subject.
• The best way to fulfil the requirements of the Open Research Data Pilot and avoid conflicts with data protection rules is to effectively anonymise personal research data before uploading them to a repository."