1\. Introduction

The FOCUS consortium aims to ensure that the highest standards of data
management, are respected throughout the project. This document sets out the
consortium’s approach to managing data that is collected, generated, and/or
used during the research.

###  1.1 Project overview

In 2015 and 2016 the EU experienced an unparalleled influx of refugees and
migrants. This has posed multiple challenges for social- and health services
and labour markets in host communities, as well as for the lives of the
refugees.

In response to this situation, the vision of the FOCUS project is to increase
understanding of, and provide effective and evidence-based solutions for, the
challenges of forced migration within host communities. This, it is believed,
will contribute to increased tolerance, peaceful coexistence, and reduced
radicalization across Europe and the Middle East.

Based on comprehensive mapping and trans-disciplinary multi-site field
research conducted in Jordan, Croatia, Germany and Sweden, FOCUS explores the
socio-psychological dimensions of refugee- and host-community relations. It
aims to determine the relation between socio-economic and socio-psychological
integration. The project will analyse the socio-economic integration of
refugees, and the consequences of this in host societies.

Knowledge developed in the project will be used to transform and strengthen
existing promising solutions for social- and labour market integration. The
integration solutions will be pilot tested in at least five European countries
by governmental and non-governmental end-users. The solutions are finally
brought together in a “Refugee and Host Community Toolbox”, which will support
policy makers, municipal actors, civil society organisations and other
stakeholders in responding to the needs of refugees and host communities.

In addition, FOCUS undertakes an ambitious programme of engagement with policy
makers, end-users, host communities, refugees and other stakeholders. This
will ensure that FOCUS research and solutions are acceptable and useful for
policy makers, while meeting the needs of end-user organisations and,
ultimately, refugees and host communities.

FOCUS is a three-year project, beginning January 2019. The project is funded
by the European Union through the Horizon 2020 research and innovation
programme (grant agreement number 822401).

###  1.2 Overview of data generated in FOCUS

A good deal of data will be generated in FOCUS. This includes:

  * data about the FOCUS project partners, such as internal communications of the consortium (including personal data), e.g. emails, meeting agendas, notes, and minutes, actions plans, working documents, etc.; 

  

  * external communications between the consortium and members of the FOCUS Advisory Board and Ethics Advisory Board (including personal data), e.g. emails, meeting agendas, notes, and minutes, actions plans, working documents, etc.; external communications between the consortium and third-party stakeholders (including personal data), e.g. EU Project Officers and appointed reviewers; 

  

  * data generated from desk research activities, e.g. mapping documents, literature reviews, thematic or policy analyses and recommendations, etc.; tools, frameworks, methodologies, training materials, and operational solutions to build trust between host communities and refugees (the “Refugee and Host Community Toolbox”); 

  

  * data (including personal data) generated from interaction with research participants, including interviewees, conference/workshop attendees, field-work participants, focus group members, survey respondents, pilot-testing participants; 

  

  * dissemination and communication materials and activities, e.g. planning/strategy/sustainability documents, promotional materials (website, presentations, posters, newsletters, press releases, articles, project-related videos, social-media output), peer-reviewed publications and conference presentations; 

  

  * metadata, of various kinds, associated with the generation, processing, or use of the any of the above categories of data or research objects. 

  

###  1.3 Data Management Plan: overview

The Data Management Plan (DMP) describes the data management life cycle for
all data collected, processed, and generated during the FOCUS project. It
provides details on:

  * the types and formats of data generated, collected, and processed during the project; • the purposes for which this data is generated, collected and processed; 

  

  * how the consortium complies with the principles of “FAIR data management” (i.e. that data should be _findable, accessible, interoperable, and reusable_ ); and how it meets its responsibilities to make its findings available through _open access_ ; 

  

  * what resources are allocated to data management in the project, and who is responsible; 

  

  * how the data is secured against loss, misuse, corruption, etc. 

  

  * ethical aspects of data management in the project and how the consortium meets its data protection responsibilities. 

  

The DMP is a living document. As such it will be updated throughout the
project, in accordance with the timeline set out in _section 1.5_ below.

###  1.4 Ethics Management Plan

Data management raises several ethical issues (concerning, e.g., privacy,
responsibilities to disseminate research findings, etc.). These are addressed
throughout the DMP. There are many other ethical issues raised by a project of
this kind. Since many of these are directly or indirectly related to data
management, and since these issues require a responsive management approach,
the DMP – as a living document – is a suitable place to record them.
Accordingly, we include as an annex to this document the project Ethics
Management Plan (EMP).

The EMP ( _section 8_ ) sets out the management structure that the consortium
has developed in order to best address ethics and research ethics requirements
(including details of the Ethics Advisory Board). It also includes brief but
detailed analysis of ethics issues and challenges that are anticipated in the
project. The consortium recognises that research involving refugees poses
particular challenges. The EMP sets out how we intend to meet these
challenges.

###  1.5 Timetable for updates

The DMP is a living document that will be updated at key moments throughout
the project. The timetable is as follows. Note, however, that we maintain
flexibility and will produce additional “unscheduled” versions of the DMP if
there are significant changes that require an immediate update.  
  
<table>  
<tr>  
<th>

**Month**

</th>  
<th>

**Date**

</th>  
<th>

**Version**

</th>  
<th>

**Comments**

</th> </tr>  
<tr>  
<td>

M7

</td>  
<td>

31 July 2019

</td>  
<td>

DMP (first issue)

</td>  
<td>

Vast majority of data collection is in future; hence this version is
indicative of plans that are not yet finalised.

</td> </tr>  
<tr>  
<td>

M24 ( _or after end of WP4 / fieldwork_ )

</td>  
<td>

31 December 2020

</td>  
<td>

DMP

(intermediate issue)

</td>  
<td>

</td> </tr>  
<tr>  
<td>

M36

</td>  
<td>

31 December 2021

</td>  
<td>

DMP (final issue)

</td>  
<td>

</td> </tr> </table>

###  1.6 This version in context

This version of the DMP is the _first issue_ . This means that it is produced
at a moment in the project when the vast majority of data collection and
analysis lies before us. Accordingly, this version is largely prospective,
less granular in detail than will be subsequent versions, and is only
indicative of our plans for good data management.

2\. Data Summary

###  2.1 Section summary

2.1.1 What is the purpose of the data collection/generation and its relation
to the objectives of the project?

The vision of the FOCUS Consortium is to increase our understanding of, and
provide effective and evidence-based solutions for, the challenges of forced
migration within host communities and thereby contribute to increased
tolerance, peaceful coexistence, and reduced radicalisation across Europe and
in the Middle East. The FOCUS project aims to conduct state-of-the-art
research on host-community-refugee relations and develop solutions for the
successful coexistence of host communities and refugees. To achieve this, the
FOCUS objectives are centred on three dimensions:

  1. Research 

  

  2. Solutions 

  

  3. Policy engagement 

  

  

The FOCUS objectives are listed in the Description of Action. For each
objective, it is indicated in which work package the objective will be
addressed and how it can be verified during the project period, if the
objective has been fulfilled.  
  
<table>  
<tr>  
<th>

**Dimension**

</th>  
<th>

**Objectives**

</th>  
<th>

**Indicators and verification method**

</th>  
<th>

**WP**

</th> </tr>  
<tr>  
<td>

Research

</td>  
<td>

1\. Contribute to the **evidence base** on understanding refugee/host
community relations through addressing the central research question: _How do
different patterns of the socio-economic integration of refugees influence the
sociopsychological dimensions of refugee- and host-community relations, and
vice-versa?_

</td>  
<td>

Comprehensive mapping of available evidence, policies and solutions on forced
migration conducted by M6.

Joint socio-economic and socio-psychological research methodology in place by
M6

Major research programme completed and reports from Jordan, Croatia, Sweden
and Germany in place by M24

A set of socio-economic and socio-psychological indicators to measure
integration are developed and pilot tested by M36

</td>  
<td>

_WP2_ _WP3_ _WP4_

</td> </tr>  
<tr>  
<td>

Solutions

</td>  
<td>

2\. **Develop and pilot test solutions** to foster peaceful coexistence
between refugees and host communities

</td>  
<td>

Refugee and Host Community Toolbox developed and pilot tested in five European
countries by M30

</td>  
<td>

_WP2_ _WP5_ _WP6_

</td> </tr>  
<tr>  
<td>

Policy engagement

</td>  
<td>

3\. Provide an overall framework for **policy makers** to adopt and adapt the
solutions and recommendations for the adoption of effective policies and
practices in diverse settings.

</td>  
<td>

At least 20 policy makers at different levels engaged throughout the project
implementation through a series of consultations and interviews.

Network of Host Communities established by M7.

Policy road map in place by M30

Guide for Adaption Solutions in place by M36

</td>  
<td>

_WP2_ _WP6_ _WP7_

</td> </tr> </table>

2.1.2 What types and formats of data will the project generate/collect?

The main types of data are: (i) outcomes of desk research (summaries,
literature reviews, analysis of existing datasets, etc.); (ii) feedback from
stakeholder workshops and similar events; (iii) responses to surveys and focus
groups carried out in fieldwork with refugees and host communities, as well as
in pilot-testing activities with end-users; (iv) content and metadata from the
online Network of Host Communities; (v) contact details of project
stakeholders. This data is held, respectively in the following formats: (i)
.docx, .pdf, .xlsx; (ii) .docx, .pdf, .xlsx; (iii) .xlsx; .csv, .sav, .sps,
.txt (iv) .csv (v) .xlsx and stored in partners’ email clients and servers.  1

2.1.3 Will you re-use any existing data and how?

We use existing, publicly available datasets (or datasets which are available
on application) in WPs 2, 3, and 4. These are analysed to provide statistical
perspectives on socio-economic and psycho-social aspects of integration. In
Sweden these come from Statistics Sweden (SB). For Germany we use Socio-
economic panel data (SOEP) which provides micro data on refugees in Germany.
2  For the data on the flow of asylum seekers we have used the publicly
available dataset of destatis  3  , as well as the dataset of the Federal
Office for Migration and refugees.  4

2.1.4 What is the origin of the data?

Primary data is gathered during fieldwork with refugees and host communities
in Jordan, Croatia, Germany, and Sweden, through pilot-testing for the
developed tools in Austria, Denmark, Germany, Sweden, and the United Kingdom,
and through various stakeholder workshop events.  5  Contact details of
stakeholders are collected from either the existing networks of project
partners or from publicly available sources. Swedish statistics come from
Statistics Sweden (SB). The German SOEP data, which will mainly be used for
the purpose of secondary data analysis In WP4 is not publicly available.
Access to the data necessitates an official contract.  6  Existing datasets
used for providing statistical perspectives on socio-economic and psycho-
social aspects of integration are publicly available. Data is contributed to
the Network of Host Communities on a voluntary basis by stakeholders.

2.1.5 What is the expected size of the data?

Data collected during the fieldwork (which is the main focal point for data
collection in the project and the only point at which we expect more than
“low” volume of data collection) is projected to amount to 2,400 host
community survey responses, 2,000 refugee survey responses, and around 16-10
focus group transcripts. Details on data minimisation in fieldwork are
provided in the Fieldwork Data Protection Impact Assessment ( _section 7.1_ ).

2.1.6 To whom might the data be useful (“data utility”)?

Data gathered in the project will be of use to researchers working in relevant
areas, organisations (NGOs, civil society organisations, etc.) active in the
field, and policy-makers.

###  2.2 Types, formats, sources/origins

The following table shows the different **types of datasets** that we expect
to collect, generate, or use in the FOCUS project, the **sources or origins**
of the data, the **format** in which the data sets will be stored, the
**volume** of data expected, the Work Packages and tasks with which the data
sets are associated, and the partners responsible for that dataset/task.
**Table 1:** Types, format and sources of datasets in FOCUS  
  
<table>  
<tr>  
<th>

**#**

</th>  
<th>

**Dataset / Type**

</th>  
<th>

**Source / Origins**

</th>  
<th>

**Format**

</th>  
<th>

**Volume**

</th>  
<th>

**WP / Task**

</th>  
<th>

**Responsible**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

**Host-community/refugee relations desk research**

</td>  
<td>

Desk research: literature reviews, policy analysis, migration data analysis

</td>  
<td>

.docx, .pdf, .xlsx,

.csv

</td>  
<td>

Low

</td>  
<td>

WP2: T2.1, T2.2, T2.3, T2.5

</td>  
<td>

**MAU** (WP2, T2.1,

T2.3, T2.5)

**FFZG** (T2.2)

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

**International (UNHCR, IOM), regional (EU), national asylum/migration flow
data**

</td>  
<td>

Publicly available datasets

</td>  
<td>

.pdf, .xlsx, .csv

</td>  
<td>

Low

</td>  
<td>

WP2: T2.5

</td>  
<td>

**MAU** (WP2,

T2.5)

</td> </tr>  
<tr>  
<td>

3

</td>  
<td>

**Policy-maker structured interviews data**

</td>  
<td>

Structured interviews with govt and non-govt policy makers at EU, MS, and
local levels

</td>  
<td>

.docx, .pdf

</td>  
<td>

Low

</td>  
<td>

WP2: T2.3

WP6: T6.1

</td>  
<td>

**MAU** (WP2,

T2.3)

**Q4** (WP6, T6.1)

</td> </tr>  
<tr>  
<td>

4

</td>  
<td>

**End-user semi-structured interviews data**

</td>  
<td>

Semi-structured interviews with endusers at local government and NGO levels

</td>  
<td>

.docx

</td>  
<td>

Low

</td>  
<td>

WP2: T2.4

</td>  
<td>

**MAU** (WP2,

T2.4)

</td> </tr> </table>  
<table>  
<tr>  
<th>

5

</th>  
<th>

**End user workshop data**

</th>  
<th>

Workshop with members of the project end-user board

</th>  
<th>

.docx, .pdf

</th>  
<th>

Low

</th>  
<th>

WP2: T2.4

</th>  
<th>

**MAU** (WP2,

T2.4)

</th> </tr>  
<tr>  
<td>

6

</td>  
<td>

**Indicators of sociopsychological and socioeconomic integration**

</td>  
<td>

Analysis of WP2 data/results

</td>  
<td>

.docx, .pdf

</td>  
<td>

Low

</td>  
<td>

WP3: T3.1

</td>  
<td>

**FFZG** (WP3,

T3.1)

</td> </tr>  
<tr>  
<td>

7

</td>  
<td>

**National integration-relevant data**

</td>  
<td>

Publicly available datasets (such as register, census, and survey data)

</td>  
<td>

.pdf, .xlsx, .csv

</td>  
<td>

Low

</td>  
<td>

WP3: T3.1

WP4: T4.5

</td>  
<td>

**FFZG** (WP3,

T3.1)

**CSS** (WP4)

**MAU** (T4.5)

</td> </tr>  
<tr>  
<td>

8

</td>  
<td>

**Methodology workshop data**

</td>  
<td>

Workshop with consortium, Advisory Board, Ethics Advisory Board

</td>  
<td>

.docx, .pdf

</td>  
<td>

Low

</td>  
<td>

WP3: T3.2

</td>  
<td>

**FFZG** (WP3,

T3.2)

</td> </tr>  
<tr>  
<td>

9

</td>  
<td>

**Fieldwork pilot testing data**

</td>  
<td>

Primary data collection from (n=20) host community members and (n=10) refugees
at each study site (Jordan,

Croatia, Germany, Sweden)

</td>  
<td>

.xlsx, .csv, .docx,

.pdf

</td>  
<td>

Low

</td>  
<td>

WP3: T3.3

</td>  
<td>

**FFZG** (WP3,

T3.3)

</td> </tr>  
<tr>  
<td>

10

</td>  
<td>

**Fieldwork survey data**

</td>  
<td>

Primary data collection, via survey, from n=600 host community member
participants and n=600 refugee participants in Jordan, German, Croatia (i.e.
1,200 in each country) and roughly n=600 host community participants and n=200
refugee participants in Croatia

</td>  
<td>

.csv, .xlsx, .sav,

.sps

</td>  
<td>

Medium

</td>  
<td>

WP4: T4.3

</td>  
<td>

**FFZG** (WP4,

T4.3)

</td> </tr>  
<tr>  
<td>

11

</td>  
<td>

**Fieldwork focus group data**

</td>  
<td>

Primary data collection via 4-5 focus groups in each country (Jordan, Croatia,
Germany, Sweden)

</td>  
<td>

.docx, .pdf, .txt

</td>  
<td>

Low

</td>  
<td>

WP4: T4.4

</td>  
<td>

**CSS** (WP4)

**HU** (T4.4)

</td> </tr>  
<tr>  
<td>

12

</td>  
<td>

**Cross-site analysis data**

</td>  
<td>

Analysis of datasets 9 & 10\.

</td>  
<td>

.xlsx, .csv, +TBC

</td>  
<td>

.xlsx, .csv,

+TBC

</td>  
<td>

WP4: T4.6

</td>  
<td>

**CSS** (WP4, T4.6)

</td> </tr> </table>  
<table>  
<tr>  
<th>

13

</th>  
<th>

**Refugee and Host Community Toolbox, version 1**

</th>  
<th>

Selection of tools identified in WP2

</th>  
<th>

.docx

</th>  
<th>

Low

</th>  
<th>

WP5: T5.1

</th>  
<th>

**DRC** (WP5, T5.1)

</th> </tr>  
<tr>  
<td>

14

</td>  
<td>

**Toolbox training seminar data**

</td>  
<td>

3-Day training seminar with pilottesting participants.

</td>  
<td>

.docx

</td>  
<td>

Low

</td>  
<td>

WP5: T5.3

</td>  
<td>

**DRC** (WP5, T5.3)

</td> </tr>  
<tr>  
<td>

15

</td>  
<td>

**Toolbox pilot test data**

</td>  
<td>

Primary data collection via pilot testing in different countries

</td>  
<td>

.xlsx, .csv, .docx

</td>  
<td>

Low

</td>  
<td>

WP5: T5.3, T5.4

</td>  
<td>

**DRC** (WP5, T5.3,

T5.4)

</td> </tr>  
<tr>  
<td>

16

</td>  
<td>

**Refugee and Host Community Toolbox, version 2**

</td>  
<td>

Refined set of tools identified in WP2, honed in WP5 & WP6

</td>  
<td>

.docx

</td>  
<td>

Low

</td>  
<td>

WP5: T5.3

WP6: T6.2

</td>  
<td>

**DRC** (WP5, T5.3,

T6.2)

**Q4** (WP6)

</td> </tr>  
<tr>  
<td>

17

</td>  
<td>

**Project videos**

</td>  
<td>

Videos taken to promote the project, which may include members of the
consortium speaking about the project, its goals and progress.

</td>  
<td>

.mp4 or similar

</td>  
<td>

Low

</td>  
<td>

WP7: T7.2, T7.4

</td>  
<td>

**ART** (WP7)

</td> </tr>  
<tr>  
<td>

18

</td>  
<td>

**CMT (consortium internal) data**

</td>  
<td>

Data (content and metadata) generated by the consortium’s use of the Community
Management Tool (CMT) for purposes of project management and interaction

</td>  
<td>

.csv & online

</td>  
<td>

Low

</td>  
<td>

WP1: T1.1

WP7

</td>  
<td>

**DRC** (WP1, T1.1)

**ART** (WP7)

</td> </tr>  
<tr>  
<td>

19

</td>  
<td>

**NHC data**

</td>  
<td>

Data (content and metadata) generated by the use of the CMT to facilitate the
Network of Host Communities (NHC); data generated from external cooperation
activities (stakeholder workshops, final

conference, etc.)

</td>  
<td>

.csv & online

</td>  
<td>

Low

</td>  
<td>

WP7: T7.1, T7.2, T7.3

</td>  
<td>

**ART** (WP7, T7.1,

T7.2, T7.3)

</td> </tr>  
<tr>  
<td>

20

</td>  
<td>

**Stakeholder, end-user,**

**Advisory Board, Ethics Advisory Board member contact details**

</td>  
<td>

Publicly available sources

</td>  
<td>

.docx, .xlsx., .csv, email-client, partner servers

</td>  
<td>

Low

</td>  
<td>

WP1: T1.1, T1.3

WP7, T7.1

</td>  
<td>

**DRC** (WP1, T1.1)

**AND** (T1.3)

**ART** (WP7, T7.1)

</td> </tr> </table>

###  2.3 Purposes, data utility

The following table specifies the **purposes** for which each of the datasets
identified in Table 1 is collected, generated, and processed, as well as the
**“data utility”** , i.e. an indication of to whom the data might be useful
(outside the specific context of the FOCUS project).

**Table 2:** Purpose and utility of datasets in FOCUS  
  
<table>  
<tr>  
<th>

**#**

</th>  
<th>

**Dataset / Type**

</th>  
<th>

**Purpose / Output**

</th>  
<th>

**Data Utility**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

**Host-community/refugee relations desk research**

_Desk research (literature reviews, policy analysis, migration data analysis,
etc.)_

</td>  
<td>

This data is collected and analysed to identify current status, trends, and
state-of-the-art knowledge on the socio-economic and sociopsychological
integration of refugees and impact of refugee migration in host societies.

This feeds into the development of the methodology (e.g. supporting
identification of research questions and relevant indicators) in WP3 for the
fieldwork to be conducted in WP4.

This feeds into the development of the Refugee and Host Community Toolbox, the
Guide for Adapting Solutions, and the Policy Roadmap developed in WP6.

Findings based on this data are presented in deliverable D2.1 ( _Mapping of
host-community/refugee relations_ ).

</td>  
<td>

This data will be useful to researchers working in relevant areas.

This data will be useful to organisations (NGOs, civil society organisations,
etc.) active in the field.

This data may be useful to policymakers.

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

**International (UNHCR, IOM), regional (EU), national asylum/migration flow
data**

_Publicly available datasets_

</td>  
<td>

This data is processed in order to map flows and patterns of asylum migration
from Syria.

This feeds into the development of the methodology (e.g. supporting
identification of research questions and relevant indicators) in WP3 for the
fieldwork to be conducted in WP4.

This feeds into the development of the Refugee and Host Community Toolbox, the
Guide for Adapting Solutions, and the Policy Roadmap developed in WP6.

Findings based on this data are presented in deliverable D2.1 ( _Mapping of
host-community/refugee relations_ ).

</td>  
<td>

Analysis and outputs based on this publicly available data will be useful to
researchers working in relevant areas.

Analysis and outputs based on this publicly available data will be useful to
organisations (NGOs, civil society organisations, etc.) active in the field.

Analysis and outputs based on this publicly available data may be useful to
policy-makers.

</td> </tr> </table>  
<table>  
<tr>  
<th>

3

</th>  
<th>

**Policy-maker structured interviews data**

_Structured interviews with govt and non-govt policy makers at EU, MS, and
local levels_

</th>  
<th>

This data is collected and processed in order to conduct a comparative
analysis of integration policies at EU, MS and local levels, including
identification of perceived gaps, challenges, and future policy directions.

This feeds into the development of the Refugee and Host Community Toolbox, the
Guide for Adapting Solutions, and the Policy Roadmap developed in WP6.

Findings based on this data are presented in deliverable D2.1 ( _Mapping of
host-community/refugee relations_ ).

</th>  
<th>

Raw data will not be retained (see section 4).

Analysis and outputs based on this data will be useful to researchers working
in relevant areas.

Analysis and outputs based on this data will be useful to organisations (NGOs,
civil society organisations, etc.) active in the field.

Analysis and outputs based on this data may be useful to policy-makers.

</th> </tr>  
<tr>  
<td>

4

</td>  
<td>

**End-user semi-structured interviews data**

Semi-structured interviews with endusers at local government and NGO levels

</td>  
<td>

Data is collected via an end-user workshop in order to identify and map tools
and solutions in implementing successful host-

community/refugee integration and to ensure the ideation of the toolbox is
inclusive of end-user needs, work processes and perspectives

This feeds into the development of the Refugee and Host Community Toolbox, the
Guide for Adapting Solutions, and the Policy Roadmap developed in WPs 5 and 6.

Findings based on this data are presented in deliverable D2.1 ( _Mapping of
host-community/refugee relations_ ).

</td>  
<td>

Raw data will not be retained (see section 4).

Analysis and outputs based on this data will be useful to researchers working
in relevant areas.

Analysis and outputs based on this data will be useful to organisations (NGOs,
civil society organisations, etc.) active in the field.

Analysis and outputs based on this data may be useful to policy-makers.

</td> </tr>  
<tr>  
<td>

5

</td>  
<td>

**End user workshop data**

_Workshop with members of the project end-user board_

</td>  
<td>

Data is collected via an end-user workshop in order to identify and map tools
and solutions in implementing successful host-

community/refugee integration and to ensure the ideation of the toolbox is
inclusive of end-user needs, work processes and perspectives.

This feeds into the pilot-testing of the Refugee and Host Community Toolbox in
WP5.

</td>  
<td>

The mapping of tools and solutions will be of interest to researchers working
in relevant areas.

The mapping of tools and solutions will be useful to organisations (NGOs,
civil society organisations, etc.) active in the field.

The mapping of tools and solutions may be useful to policy-makers.

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

This feeds into the development of the Refugee and Host Community Toolbox, the
Guide for Adapting Solutions, and the Policy Roadmap developed in WP6.

Findings based on this data are presented in deliverable D2.1 ( _Mapping of
host-community/refugee relations_ ).

</th>  
<th>

</th> </tr>  
<tr>  
<td>

5

</td>  
<td>

**Indicators of socio-psychological and socio-economic integration**

_Analysis of WP2 data/results_

</td>  
<td>

Data will be collected and analysed in WP3 (based on findings from WP2) in
order to identify the most appropriate indicators of sociopsychological
integration and socio-economic effects of refugee migration and integration,
as well as to define precise research questions for the fieldwork in WP4
concerning factors of sociopsychological integration such as attitudes,
perception and contact between host communities and refugees and the relation
of these indicators to those of socio-economic integration.

The collection and analysis of this data is essential to research design in
the project.

Findings and developments based on this data are presented in deliverable D3.1
( _Research design and methodology_ ).

</td>  
<td>

The research questions and indicators identified may be of interest to
researchers working in relevant areas.

</td> </tr>  
<tr>  
<td>

7

</td>  
<td>

**National integration-relevant data**

_Publicly available datasets (such as register, census, and survey data)_

</td>  
<td>

Data will be collected and analysed in WP3 (based on findings from WP2) in
order to identify the most appropriate indicators of sociopsychological
integration and socio-economic effects of refugee migration and integration,
as well as to define precise research questions for the fieldwork in WP4
concerning factors of sociopsychological integration of refugees in host
communities, as well as the related socio-economic factors influencing
integration on a local level.

The collection and analysis of this data is essential to research design in
the project.

Findings and developments based on this data are presented in deliverable D3.1
( _Research design and methodology_ ).

The data will also be used to perform statistical analysis in support of
country-reports and a cross-country comparative report on the socioeconomic
integration of refugees in local communities and the socio-

</td>  
<td>

The research questions and indicators identified may be of interest to
researchers working in relevant areas.

The four country reports and the cross-site analysis report based on this data
will be of interest to researchers working in relevant areas.

The four country reports and the cross-site analysis report based on this data
will be of interest to organisations (NGOs, civil society organisations, etc.)
active in the field.

The four country reports and the cross-site analysis report based on this data
may be useful to policy-makers.

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

economic effects of refugee migration and integration on the host communities
on a set of factors such as the ones described in WP3.

The four country reports and the cross-site analysis report based on this data
will be presented in deliverable D4.3 ( _Cross-site analysis_ ).

</th>  
<th>

</th> </tr>  
<tr>  
<td>

8

</td>  
<td>

**Methodology workshop data**

_Workshop with consortium, Advisory_

_Board, Ethics Advisory Board_

</td>  
<td>

This data is collected in order to refine and improve the research design for
the project fieldwork. Feedback from consortium members, as well as members of
the Advisory Board and Ethics Advisory Board will be collected, assessed, and
integrated into the methodology as appropriate.

The collection and analysis of this data is essential to research design in
the project.

Findings and developments based on this data are presented in deliverable D3.1
( _Research design and methodology_ ).

</td>  
<td>

The research questions and indicators identified may be of interest to
researchers working in relevant areas.

</td> </tr>  
<tr>  
<td>

9

</td>  
<td>

**Fieldwork pilot testing data**

_Primary data collection from (n=20) host community members and (n=10)
refugees at each study site (Jordan,_

_Croatia, Germany, Sweden)_

</td>  
<td>

This data is feedback on the survey procedure, needed in order to check the
suitability of the research methodology and approach developed in WP3. This is
an essential pre-step to ensure that the fieldwork conducted in WP4 is
successful. Certain elements of the WP4 research design, such as the
formulation or language adaptation of instruments may be altered based on this
data to ensure applicability in the main fieldwork study

</td>  
<td>

Due to its low volume, and the fact that survey responses are not retained,
the data itself is not useful outside the context of the project.

</td> </tr>  
<tr>  
<td>

10

</td>  
<td>

**Fieldwork survey data**

_Primary data collection, via survey, from n=600 host community member
participants and n=600 refugee participants in Jordan, German, Croatia (i.e.
1,200 in each country) and n=200 in Croatia_

</td>  
<td>

This data is collected in order to study the socio-psychological dimensions of
the host community and refugee relations and to analyse the socio-economic
integration of refugees and the consequences of this in the host societies.

The contents of the survey will be determined in WP3 and will focus on socio-
psychological issues such as intergroup relations, perceptions of intergroup
threat, intergroup contacts, social distance and social networking across the
host and refugee groups, views towards social integration and acculturation,
perceptions of the socio-economic effects (costs and benefits) of social and
labour integration of refugees.

The survey will take in consideration a representative sample of a minimum of
600 host community members and 600 refugee

</td>  
<td>

This data will be of great interest to researchers working in relevant areas.

Findings based on this data will be useful to organisations (NGOs, civil
society organisations, etc.) active in the field.

Findings based on this data may be useful to policy-makers.

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

community members in each country with the exception of Croatia, where the
sample size of refugees will be 200 people due to the comparatively low number
of refugees from Syria. This sample size is sufficient to reach a 0.95
confidence level with +/- 4% marginal error (confidence interval) and in
Croatian refugee sample the confidence interval of +/- 5%.

**_Study sites_ **

Four study sites (Germany, Sweden, Croatia, Jordan), focusing on communities
with high concentration and number of refugees.

**_Target groups_ **

Target groups are host community members and refugees from Syria. The target
group of refugees from Syria is described as forced migrants from Syria who
have been recognized as refugees by UNHCR from 2011 onward in Jordan, or have
received the international protection status (asylum) from 2015 onward for
European countries, and have been living in respective host communities from
the point of receiving this status to date. Inclusion criteria are:

  * Age (between 18 and 65 years). 

  

  * Refugee/asylum status (must have received positive decision regarding their status). 

  

  * Year of receiving refugee status (received after 2015 (2011 in Jordan) qualify for the study). In Jordan the applicable criteria for acknowledging the refugee status will be used. 

  

  * Not living in a camp/shared accommodation for refugees. 

  

Host community members are defined as persons who have citizenship or
permanent residency in the respective European country and have been living in
the same host community for at least 7 years (at least since 2013, i.e. two
years prior to the beginning of the migration wave from Syria to Europe). For
Jordan, the host community members are defined as Jordanians, as in Jordan
foreigners cannot receive citizenship or permanent residence. Inclusion
criteria are:

  * Age (between 18 and 65 years). 

  

</th>  
<th>

</th> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

  * Number of years living in the respective country (more than 7). 

  

  * Citizenship or residence (must have one). 

  

Exclusion criteria are:

  * Health conditions that prevent normal communication in Arabic or the language of the host community 

  

  * Failure to provide informed consent 

  

  * Inability to reach the identified target participant after three attempts 

  

  * Participants’ refusal to be contacted. 

  

**_Sampling host community participants_ **

Survey of host community members will use two probabilistic sampling
techniques to select the participants. Due to differences among the four sites
with access to registers of host community members, the Random Walk Technique
(RWT) will be used in Germany, Jordan and Croatia. In Sweden, citizen
registries will be used for randomised selection of participants and the
validated interviewing procedures will be followed as in other similar
population based studies in Sweden.

In the selected target areas (regions, cities) the sample size will be
proportional to population. Participants will be selected by probability
sampling to ensure the sample structure reflects the areas’ population
characteristics based on available statistics, such as the total male and
female population in the 18 to 65 age group.

The host community members will be sampled using the sampling frame that will
ensure the full probabilistic representativeness. The sampling protocol will
use cluster sampling with several levels of clusters: 1) target geographical
and political entities in each country with highest concentration and number
of Syrian refugees (governorates in Jordan, Federal states in Germany,
counties in

Croatia, municipalities in Sweden), 2) among these clusters select cities with
highest number of refugees, 3) implement a randomized procedure of recruiting
participants using national registries where available and permitted (such as
Statistics Sweden) or the standard random walk technique (RWT) with several
local starting points within

</th>  
<th>

</th> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

the selected cities to ensure probabilistic sample composition that will
reflect the population parameters.

**_Sampling refugee participants_ **

The sampling design for the refugee survey will aim at achieving heterogeneity
to reflect the refugee population parameters, but true probabilistic sampling
is not expected at all study sites. RWT of sampling refugee respondents will
be used if possible in Jordan, while random sampling of refugees based on
registries will be used in Sweden. In Germany and Croatia refugee respondents
will be approached through NGOs that maintain contact with them and if needed
with advertisements and invitations to participate in the study that will be
placed at locations frequented by refugees from Syria.

During initial contact with potential refugee participants the

Information Letter about the study and invitation to participate will be
distributed through NGO channels. Willing participants will send message
through the NGO intermediaries and will then be contacted.

To minimise potential self-selection and other referral biases, in each area
(region, city) at least five different entry points into the target population
(i.e. NGOs, locations for placing the advertisements and invitations to
participate in the study) will be used.

The refugee study participants will be recruited within the same host
communities as described above. They will be identified using available
national registries where available and permitted (such as Statistics Sweden)
or through partners’ various professional field channels such as social
services, local Red Cross and similar care organizations, and refugee
community groups.

The potential participants will be approached using a combination of
information channels (online, printed, verbal) and invited to participate in
the study.

**_Data collection_ **

Data collection will be conducted in a comparable way across countries using
standard and validated procedures, such as computer assisted telephone
interviewing (CATI), computer assisted personal

</th>  
<th>

</th> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

interviewing (CAPI), or face-to-face paper and pencil interview in the
language preferred by the participants, using the same questionnaire, and in
all cases carried out by trained staff.

**_Quality assurance during data collection_ **

While gathering data, the interviewers will maintain a separate “survey log”
in the paper format for each completed and attempted interview. In this log
they will note the address, time, date and outcome of each completed or
attempted interview, whether original or replacement household.

At the end of the interview, the participants will be asked if they agree to
be contacted by the survey supervisor for the purpose of monitoring the work
of the interviewers. If the participant agrees, his/her phone number will be
written in the specific follow-up table together with the participant’s
personal code. This will enable the survey supervisor to verify about 10 % of
the completed interviews per each interviewer. The telephone numbers will be
randomly selected among the participants who have agreed to be called back. If
selected for the follow-up call, the supervisor will ask the participant if
he/she was interviewed during the previous three days at home (or in case of
refugee participants possibly at other locations) by means of a tablet about
the integration of host community members and refugees. The supervisor will
not be able to identify the individual participant.

In case of irregularities, the personal code will serve to delete this
participant’s data. In such a case, all other interviews done by the same
interviewer will be also deleted. Such interviewer will be immediately
dismissed and other interviewers will collect data from the replacement
households and participants.

The survey logs will be kept separate from the participants’ responses which
will be entered into the tablet computer during the interview and in no way
will they be linked to the data of an individual participant.

To avoid interviewer bias, none of the interviewers will interview more than
15% of the sample, i.e. a maximum of 90 participants from at least nine
sampling points.

</th>  
<th>

</th> </tr> </table>  
<table>  
<tr>  
<th>

11

</th>  
<th>

**Fieldwork focus group data**

_Primary data collection via 4-5 focus groups in each country (Jordan,_

_Croatia, Germany, Sweden)_

</th>  
<th>

Focus group data is required in order to provide illustrative and profound
information about host community and refugee integration gaps, opportunities
and solutions. This data is collected in order to study the socio-
psychological dimensions of the host community and refugee relations and to
analyse the socio-economic integration of refugees and the consequences of
this in the host societies.

Participants in the qualitative part of the study will be recruited into 4 to
5 focus groups of key informants among the host and refugee community members
in the same cities where the quantitative survey will be done. Both host and
refugee participants will be identified among the general population using
different information channels and reaching out to, for example, schools, work
places, welfare services, job services and other locations where the potential
participants will be approached. The key informants will be defined as
individuals (both women and men, between 18 and 65 years of age), who have
been living in the respective community at least two seven past years, are
aware of the presence of refugees living in the community, and are able to
articulate their experiences and views. The principle of maximal heterogeneity
regarding the age, education level and gender will guide the recruitment of
focus groups composition.

The focus groups will be held in the mother tongue of the participants. The
topics will address the same issues as addressed in the survey. It is expected
that 4 to 5 focus groups with host representatives and with refugee
representatives with 5 to 8 members in each group should be sufficient to
achieve the theoretical saturation of data at each study site. Should this
number prove not to be enough, further data collection will be done until such
criterion is achieved. Findings based on this data are presented in
deliverable D4.2 ( _Qualitative studies in host-communities_ ).

</th>  
<th>

Raw data (transcripts of focus groups) will not be retained as only of use
within the context.

The analysis and output based on it will be shared as it may be useful to
researchers working in relevant areas, organisations (NGOs, civil society
organisations, etc.) active in the field, and policy-makers.

</th> </tr>  
<tr>  
<td>

12

</td>  
<td>

**Cross-site analysis data**

_Analysis of datasets 9 & 10\. _

</td>  
<td>

This data is collected in order to study the socio-psychological dimensions of
the host community and refugee relations and to analyse the socio-economic
integration of refugees and the consequences of this in the host societies.

</td>  
<td>

This data will be useful to researchers working in relevant areas.

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

Country-level and cross-site analyses are valuable due to the variety of
cultural and socioeconomic contexts in which the interaction of refugees and
hosting communities occurs. Analysis of datasets 9 & 10 in the light of
country-related issues will enable the consortium to discern common and
divergent findings, including their critical interpretation. This analysis
will take into account the different types of policies that each country
implemented.

Findings based on this data are presented in deliverable D4.3 ( _Crosssite
analysis_ ).

</th>  
<th>

This data will be useful to organisations (NGOs, civil society organisations,
etc.) active in the field.

This data may be useful to policymakers.

</th> </tr>  
<tr>  
<td>

</td>  
<td>

**Secondary micro and aggregate data**

_Complementary to the survey data_

</td>  
<td>

This data will be sourced from the Swedish administrative data and German Soep
data. The analysis of secondary data will be used to validate the survey data.

</td>  
<td>

This data will be of use only in the context of the project.

</td> </tr>  
<tr>  
<td>

13

</td>  
<td>

**Refugee and Host Community Toolbox, version 1**

_Selection of tools identified in WP2_

</td>  
<td>

This data (a selection of tools, solutions, methods, approaches, etc. for

encouraging/enhancing trust and integration between hostcommunities and
refugees) is collected in order to begin the development of the first version
of one of the major project outcomes: the Refugee and Host Community Toolbox
(version 1).

The Refugee and Host Community Toolbox will enable municipal actors, civil
society organisations and other stakeholders to foster dialogue and build
trust and resilience among refugees and host communities. The solutions are
based on group and individual models that integrates labour market approaches
to integration with social and psychosocial aspects of integration. The
toolbox will include a focus on local helpers providing practical guidance,
opening doors to local networking, and providing cultural and linguistic
interpretation easing the way into the society and community.

The solutions are identified in the mapping of existing literature, policies
and solutions (WP2), the multi-site research exploring the socio-psychological
dimensions of refugee- and host-community relations and the socio-economic
integration of refugees (WP4), ) and,

</td>  
<td>

The first version of the Refugee and Host Community Toolbox will be of
interest mainly within the consortium.

Later versions of the Toolbox will be of interest to researchers working in
relevant areas.

Later versions of the Toolbox will be useful to organisations (NGOs, civil
society organisations, etc.) active in the field.

Later versions of the Toolbox may be useful to policy-makers.

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

in order to remain current, as an integral part of the development and
adaptation work of the toolbox (WP5).

</th>  
<th>

</th> </tr>  
<tr>  
<td>

14

</td>  
<td>

**Toolbox training seminar data**

_3-Day training seminar with pilottesting participants_

</td>  
<td>

Data will be collected from a three-day training seminar, that will be
organised for level 2 pilot organisations to be trained in the Refugee and
Host Community Toolbox before they conduct the pilot tests in their respective
countries.

Data from the training seminar is necessary both to support improvement of the
Toolbox, and to improve training methods.

</td>  
<td>

This data will be of use only in the context of the project.

</td> </tr>  
<tr>  
<td>

15

</td>  
<td>

**Toolbox pilot test data**

_Primary data collection via pilot testing in different countries_

</td>  
<td>

Data will be collected from pilot-testing of the Refugee and Host Community
Toolbox with end-users in different countries. The data will be feedback on
the use of the Toolbox.

Analysis of this data (the results of the pilot tests) will result in
essential recommendations for improvements and updates of the operational
level solutions (i.e. the contents of the Toolbox).

The Refugee and Host Community Toolbox will be finalised and presented in
deliverable D6.2 ( _Refugee & Host Community Toolbox _ ).

</td>  
<td>

The pilot-test data will be of use only in the context of the project.

The Refugee and Host Community Toolbox, based, _inter alia_ , on the pilot-
test data, will be of interest to researchers working in relevant areas.

The Refugee and Host Community Toolbox, based, _inter alia_ , on the pilot-
test data, will be of great interest to organisations (NGOs, civil society
organisations, etc.) active in the field.

The Refugee and Host Community Toolbox, based, _inter alia_ , on the pilot-
test data, will be of interest to policy-makers.

</td> </tr>  
<tr>  
<td>

16

</td>  
<td>

**Refugee and Host Community Toolbox, version 2**

_Refined set of tools identified in WP2,_

_honed in WP5 & WP6 _

</td>  
<td>

The Refugee and Host Community Toolbox will be finalised and presented in
deliverable D6.2 ( _Refugee & Host Community Toolbox _ ).

</td>  
<td>

The Refugee and Host Community

Toolbox will be of interest to researchers working in relevant areas.

The Refugee and Host Community

Toolbox will be of great interest to organisations (NGOs, civil society
organisations, etc.) active in the field.

</td> </tr>  
<tr>  
<td>

</td>  
<td>

</td>  
<td>

</td>  
<td>

The Refugee and Host Community Toolbox will be of interest to policymakers.

</td> </tr>  
<tr>  
<td>

17

</td>  
<td>

**Project videos**

</td>  
<td>

Videos taken to promote the project, which may include members of the
consortium speaking about the project, its goals and progress.

</td>  
<td>

The data is of interest to other parties and available on the project website.

</td> </tr>  
<tr>  
<td>

18

</td>  
<td>

**CMT (consortium internal) data**

_Data (content and metadata) generated by the consortium’s use of the
Community Management Tool (CMT) for purposes of project management and
interaction_

</td>  
<td>

This data includes all communications, records of meetings, planning
documents, etc. generated in the project. Such data is essential to
organising, managing, and carrying out the project.

</td>  
<td>

This data is of no use outside the consortium.

</td> </tr>  
<tr>  
<td>

19

</td>  
<td>

**NHC data**

_Data (content and metadata) generated by the use of the CMT to facilitate the
Network of Host Communities (NHC); data generated from external cooperation
activities (stakeholder workshops, final conference, etc.)_

</td>  
<td>

The project is ambitious in terms of stakeholder engagement: it aims to
establish an active Network of Host Communities in the field of migration and
forced displacement that will be sustainable in the future. This network shall
connect stakeholders (organisations and individuals) dealing with forced
displacement and facilitate the implementation of policies and the uptake of
research and innovation by end-users. Contact details used by individuals and
organisations to sign up to the NHC, the content (and its associated metadata)
that they upload to the network (using the CMT), are required to ensure that
the NHC is active and engaged. Contact details, as well as content developed
for and from network events (stakeholder workshops, final project conference,
etc.) are similarly required to ensure that members of the NHC are active and
engaged. Encouraging this level of engagement is necessary in order to promote
the long-term sustainability of the NHC.

</td>  
<td>

Data from the NHC will be of use to the NHC members (i.e. various stakeholders
in the field of migration and asylum).

</td> </tr>  
<tr>  
<td>

20

</td>  
<td>

**Stakeholder, end-user, Advisory Board, Ethics Advisory Board member contact
details**

_Publicly available sources_

</td>  
<td>

This data is necessary in order to run the project advisory boards and to
support stakeholder engagement with the project.

</td>  
<td>

This data is of use only in the context of the project.

</td> </tr> </table>

3\. FAIR data

FOCUS complies with the principles of FAIR data management, i.e. that as much
as possible of our research data is **findable, accessible, interoperable, and
reusable** . This section sets out how we intend to ensure this compliance.

###  3.1 Findability: making data findable, including provisions for metadata

**Table 3:** Findability of datasets in FOCUS  
  
<table>  
<tr>  
<th>

**#**

</th>  
<th>

**Dataset / Type**

</th>  
<th>

**Data available ? (y/n)**

</th>  
<th>

**Format in which data is openly available**

</th>  
<th>

**Where is the data available?**

</th>  
<th>

**Metadata / identifiers**

</th>  
<th>

**Keywords**

</th>  
<th>

**Naming convention (includes versioning)**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

**Hostcommunity/refugee relations desk research**

</td>  
<td>

Yes

</td>  
<td>

**Report** : D2.1

</td>  
<td>

Zenodo  7  , FOCUS community space.

</td>  
<td>

Title, author(s), publication date, DOI, keyword(s), funding source and GA
no., title and acronym of action.

</td>  
<td>

TBC

</td>  
<td>

_lead_ \- _author_ -etal_yyyy_[ _shortened_

\- _title_ _v _1.0_

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

**International (UNHCR, IOM), regional (EU),**

</td>  
<td>

Yes

</td>  
<td>

Publicly available datasets

</td>  
<td>

na

</td>  
<td>

na

</td>  
<td>

na

</td>  
<td>

na

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

**national**

**asylum/migration flow data**

</th>  
<th>

</th>  
<th>

</th>  
<th>

</th>  
<th>

</th>  
<th>

</th>  
<th>

</th> </tr>  
<tr>  
<td>

3

</td>  
<td>

**Policy-maker structured interviews data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Legal/contractual** _ : This includes personal data and so is not shared in raw form for reasons of privacy and data protection. 

  

  * _**Mitigation** _ : Note that analyses based on this data are reported in D2.1 (see line 19 below). 

  

</td> </tr>  
<tr>  
<td>

4

</td>  
<td>

**End-user semistructured interviews data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Legal/contractual** _ : This includes personal data and so is not shared in raw form for reasons of privacy and data protection. 

  

  * _**Voluntary** _ : It is also of limited use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D2.1 (see line 19 below). 

  

</td> </tr>  
<tr>  
<td>

5

</td>  
<td>

**End user workshop data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Legal/contractual** _ : This includes personal data and so is not shared in raw form for reasons of privacy and data protection. 

  

  * _**Voluntary** _ : It is also of limited use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D2.1 (see line 19 below). 

  

</td> </tr>  
<tr>  
<td>

6

</td>  
<td>

**Indicators of sociopsychological and socio-economic integration**

</td>  
<td>

Yes

</td>  
<td>

**Report** : D2.1

</td>  
<td>

Zenodo, FOCUS community space.

</td>  
<td>

Title, author(s), publication date, DOI, keyword(s), funding source and GA
no., title and acronym of action.

</td>  
<td>

TBC

</td>  
<td>

_lead_ \- _author_ -etal_yyyy_[ _shortened_

\- _title_ _v _1.0_

</td> </tr>  
<tr>  
<td>

7

</td>  
<td>

**National integrationrelevant data**

</td>  
<td>

Yes

</td>  
<td>

Publicly available datasets

</td>  
<td>

na

</td>  
<td>

na

</td>  
<td>

na

</td>  
<td>

na

</td> </tr>  
<tr>  
<td>

8

</td>  
<td>

**Methodology workshop data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

</th>  
<th>

  * _**Legal/contractual** _ : This includes personal data and so is not shared in raw form for reasons of privacy and data protection. 

  

  * _**Voluntary** _ : It is also of limited use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D3.1 (see line 19 below). 

  

</th> </tr>  
<tr>  
<td>

9

</td>  
<td>

**Fieldwork pilot testing data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Voluntary** _ : This is of limited or no use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D3.1 (see line 19 below). 

  

</td> </tr>  
<tr>  
<td>

10

</td>  
<td>

**Fieldwork survey data**

</td>  
<td>

Yes (personal data removed)

</td>  
<td>

**Report** : D4.1 + anonymised dataset

</td>  
<td>

Zenodo, FOCUS community space.

</td>  
<td>

Title, author(s), publication date, DOI, keyword(s), funding source and GA
no., title and acronym of action.

</td>  
<td>

TBC

</td>  
<td>

_lead_ \- _author_ -etal_yyyy_[ _shortened_

\- _title_ _v _1.0_

</td> </tr>  
<tr>  
<td>

11

</td>  
<td>

**Fieldwork focus group data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Voluntary** _ : This is of limited or no use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D3.1 (see line 19 below). 

  

</td> </tr>  
<tr>  
<td>

12

</td>  
<td>

**Cross-site analysis data**

</td>  
<td>

Yes (personal data removed)

</td>  
<td>

**Report** : D4.3

</td>  
<td>

Zenodo, FOCUS community space.

</td>  
<td>

Title, author(s), publication date, DOI, keyword(s), funding source and GA
no., title and acronym of action.

</td>  
<td>

TBC

</td>  
<td>

_lead_ \- _author_ -etal_yyyy_[ _shortened_

\- _title_ _v _1.0_

</td> </tr>  
<tr>  
<td>

13

</td>  
<td>

**Refugee and Host Community Toolbox,**

**version 1**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Voluntary** _ : This is a preliminary version of the Toolbox. 

  

  * _**Mitigation** _ : The final version will be openly available and reported D6.2 (see lines 15 & 19 below). 

  

</td> </tr> </table>  
<table>  
<tr>  
<th>

14

</th>  
<th>

**Toolbox training seminar data**

</th>  
<th>

No

</th>  
<th>

**Justification** :

  * _**Voluntary** _ : This is of limited or no use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D6.2 (see lines 15 & 19 below). 

  

</th> </tr>  
<tr>  
<td>

15

</td>  
<td>

**Toolbox pilot test data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Voluntary** _ : This is of limited or no use outside the project context. 

  

  * _**Mitigation** _ : Note that analyses based on this data (wholly anonymised) are reported in D6.2 (see lines 15 & 19 below). 

  

</td> </tr>  
<tr>  
<td>

16

</td>  
<td>

**Refugee and Host Community Toolbox, version 2**

</td>  
<td>

Yes

</td>  
<td>

**Report** : D6.2

</td>  
<td>

Zenodo, FOCUS community space.

</td>  
<td>

Title, author(s), publication date, DOI, keyword(s), funding source and GA
no., title and acronym of action.

</td>  
<td>

TBC

</td>  
<td>

_lead_ \- _author_ -etal_yyyy_[ _shortened_

\- _title_ _v _1.0_

</td> </tr>  
<tr>  
<td>

17

</td>  
<td>

**Project videos**

</td>  
<td>

Yes

</td>  
<td>

**Online video**

</td>  
<td>

Project website

</td>  
<td>

na

</td>  
<td>

na

</td>  
<td>

_na_

</td> </tr>  
<tr>  
<td>

18

</td>  
<td>

**CMT (consortium internal) data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Voluntary** _ : This is of limited or no use outside the project context. 

  

  * _**Mitigation** _ : Insofar as this data relates to project outcomes, it is covered by line 19 below. 

  

</td> </tr>  
<tr>  
<td>

19

</td>  
<td>

**NHC data**

</td>  
<td>

No

</td>  
<td>

**Justification** :

  * _**Legal/contractual** _ : This includes personal data and so is not shared in raw form for reasons of privacy and data protection and compliance with the CMT terms of use. 

  

  * _**Voluntary** _ : It is also of very limited interest to people who are not already members, or interested in becoming a member, of the NHC itself. 

  

  * _**Mitigation** _ : Data with value to the community is largely available to NHC members through the platform. 

  

</td> </tr>  
<tr>  
<td>

20

</td>  
<td>

**Stakeholder, end-user,**

**Advisory Board, Ethics Advisory Board member contact details**

</td>  
<td>

No

</td>  
<td>

**Justification** :

\- _**Legal/contractual** _ : This includes personal data and so is not shared
in raw form for reasons of privacy and data protection.

</td> </tr> </table>  
<table>  
<tr>  
<th>

21

</th>  
<th>

**All project deliverables and related publications**

</th>  
<th>

Yes

</th>  
<th>

**Project deliverables**

**Peer-reviewed publications**

</th>  
<th>

Zenodo, FOCUS community space.

</th>  
<th>

Title, author(s), publication date, DOI, keyword(s), funding source and GA
no., title and acronym of action.

</th>  
<th>

TBC

</th>  
<th>

_lead_ \- _author_ -etal_yyyy_[ _shortened_

\- _title_ _v _1.0_

</th> </tr> </table>

###  3.2 Accessibility: making data openly accessible

Data that is not to be made openly accessible is listed above (see Table 3).
Open access to data will be provided via the Zenodo repository, using a
designated FOCUS community space (no special software or other tools are
necessary beyond standard browser and office programmes). Full instructions on
how to use the repository are available on the site. All peer-reviewed journal
articles that are published will be either be directly available via open
access on the journal website, or else authors versions will be available
within 12 months  8  of their publication in Zenodo.

Where access to data is restricted this is either (i) because it is of limited
utility outside the context of the FOCUS project or (ii) because personal data
is involved and, as a matter of best practice and compliance in data
protection, we cannot share data subjects’ personal data. In case (i) there is
simply no value to the community in making the data accessible. In case (ii),
we have either made the datasets available with only anonymised data or have
ensured that the outcomes/analyses of the data are accessible in such a way as
to reveal no personal data.  9

We have not provided instructions on how to gain access to restricted data as
there is no reason anybody should need access. Similarly, there is no
requirement for a data access committee, or for measures to record access
requests. In the unlikely event that an equivalent to a data access committee
is required, the project Steering Committee will take that role, with advice
also sought from the Ethics Advisory Board.

###  3.3 Interoperability: making data interoperable

The data generated in the project falls, broadly, into two categories: (i)
qualitative or reportbased data; and (ii) quantitative or database-based data.
The former includes all project deliverables; the latter includes the raw data
(anonymised) from fieldwork conducted in WP4.

All qualitative or report-based data is stored in standard .docx and .pdf
formats. These are readable by all modern computers with standard software
installed (including freely available software). All quantitative or database-
based data is stored in .xlsx or .csv formats.  10  Again, these are readable
by all modern computers with standard software, and are amenable to simple
exchange and re-combination with different datasets by other researchers.
Standard data and metadata vocabularies will be used in order to allow for
inter-disciplinary interoperability.  11

###  3.4 Reusability: increasing data re-use (through clarifying licences)

The datasets and deliverables generated in the project will be shared under a
Creative Commons Attribution 4.0 International licence.  12  This allows users
to _**share** _ (copy and redistribute the material in any medium or format)
and _**adapt** _ (remix, transform, and build upon the material for any
purpose, even commercially) under conditions of _**attribution** _ (they must
give appropriate credit, provide a link to the license, and indicate if
changes were made; they may do so in any reasonable manner, but not in any way
that suggests the licensor endorses them or their use) and _**no additional
restrictions** _ (they may not apply legal terms or technological measures
that legally restrict others from doing anything the license permits). This
broad licensing is intended allow the maximum value to be gained from FOCUS
data by the research community.

Publications produced in the course of the project will be published under
open access terms and will be uploaded to Zenodo.

All datasets and deliverables will be uploaded to Zenodo within 1 year of
their production. The date of production will be signalled either by the date
of submission to the European Commission (for deliverables), or the closure
date of the associated WP (for datasets). This 1 year period is a maximum (we
will strive to make data accessible considerably sooner if possible) and is
designed to allow the consortium researchers adequate time to publish their
findings.

Prior to deliverables or datasets being uploaded to Zenodo, the relevant WP
leader will ensure that quality assurance procedures have been respected. The
whole consortium will be informed in advance of uploading and will have time
to object (on some reasonable ground,

e.g. to allow time to publish); in case of disputes, the project Steering
Committee will decide in accordance with its standard procedures.

Deliverables or datasets uploaded to Zenodo will be available for re-use
indefinitely. Research artefacts uploaded to Zenodo are not editable. However,
as a means of quality assurance, in case any project deliverable or dataset is
updated having been uploaded, the latest version will be uploaded too (with
its own DOI and other metadata, and a clear version number).

4\. Allocation of resources

The consortium has allocated resources to the implementation of this data
management plan as follows.

###  4.1 Maintenance of the DMP and responsibility for oversight

Responsibility for drafting and updating the DMP lies with AND, who have been
allocated PMs for this task in WP1. All other partners have sufficient
resources to dedicate time to reviewing and contributing to the DMP. (In
general, each beneficiary has a fair number of person months (PMs), sufficient
to allow for the efforts of time that are required to ensure that the DMP is
properly implemented.)

Ultimate responsibility for ensuring that the DMP is respected lies with DRC,
as project coordinator, and, more generally, with the project Steering
Committee.

The main contact points for any questions concerning the DMP are:

  * Andrew Rebera (AND), FOCUS ethics manager 

  

  * Martha Bird (DRC), FOCUS project coordinator 

  

###  4.2 Costs of ensuring FAIR data management

The cost of publishing open access in a journal which is not open access by
default is typically between 1,000 and 2,000 EUR. Only one FOCUS beneficiary
(DRC) has budgetary resources (2,000 EUR) explicitly dedicated to the costs
associated with open access publishing.

Given that by no means all the highest-impact-factor journals are open access,
partners wishing to publish will have to either:

  * find suitable open access journals; 

  

  * meet the costs from their own institutions’ resources; 

  

  * transfer budget from elsewhere in the consortium’s overall resources. 

  

We recognise that this is not ideal. It has been identified as an issue that
should be addressed at the next project Steering Board meeting and will be
updated in the next version of the DMP.

Note that there are no ongoing costs associated with the use of the Zenodo
repository.

5\. Data security

In this section we discuss data security in the sense of _securing the project
research data against loss or corruption_ . We will not here discuss data
security in the context of data protection (i.e. protection of _personal data_
). The latter is discussed in Section 7 below.

###  5.1 Measures to ensure data security

Each partner is responsible for ensuring the security of the data they collect
or generate in the course of the research (See Table 4 for a list of
identified issues and recommended measures to ensure security of data
collected or generated in the course of the research). Each partner will
follow the data security policies prescribed by their own organisation, with
the provision that the following minimum standards will be respected.

**Table 4:** Recommended measures to ensure the security of the data.  
  
<table>  
<tr>  
<th>

**Issue**

</th>  
<th>

**Measures**

</th> </tr>  
<tr>  
<td>

Digital data backups

</td>  
<td>

All electronic data will be backed up on at least one physically distinct
medium (e.g. on a separate server, external hard drive, etc.)

</td> </tr>  
<tr>  
<td>

Physical data backups

</td>  
<td>

All physical data (e.g. papers, informed consent forms, etc.) will be stored
in a secure environment.

</td> </tr>  
<tr>  
<td>

Recovery procedures (non-personal data)

</td>  
<td>

In case data is lost, the partner will submit a description of the event to
the coordinator and the ethics manager (who are responsible for overseeing
implementation of the DMP). The data will be recovered from the available
backups, and new backups created.

</td> </tr>  
<tr>  
<td>

Recovery procedures (personal data)

</td>  
<td>

In case personal data is lost, the partner will submit a description of the
event to the coordinator and the ethics manager (who are responsible for
overseeing implementation of the DMP). The data will be recovered from the
available backups, and new backups created. The ethics manager, with the
support of the Ethics Advisory Board and Steering Committee, will make a
recommendation on whether further steps (e.g. notification of the data
subjects or data protection authorities) are required.

</td> </tr>  
<tr>  
<td>

Protection of sensitive materials

</td>  
<td>

Any personal, confidential, or otherwise sensitive electronic data will be
stored in an encrypted format; any personal, confidential, or otherwise
sensitive physical data will be stored in a locked drawer or filing cabinet
(etc.).

</td> </tr>  
<tr>  
<td>

Access control

</td>  
<td>

All project data, whether personal or not, sensitive or not, will, insofar as
it is stored by partners, be subject to strict access control. Only persons
engaged in the project by the partner will be given access to project data,
and then only with the permission of an authorised team member of the relevant
partner. Once data is deposited in the Zenodo repository, it will

</td> </tr>  
<tr>  
<td>

</td>  
<td>

be publicly available. This data is not subject to access control (but note
that this data will not include any personal data).

</td> </tr>  
<tr>  
<td>

Data transfers (general)

</td>  
<td>

There will be no sharing of personal data from fieldwork between partners
within EU Member. Any such data will be anonymised prior to transfer. The
partners will, in general, keep non-personal data sharing to a minimum. For
additional security, only encrypted data will be transferred.

</td> </tr>  
<tr>  
<td>

Data transfers (outside EU)

</td>  
<td>

Fieldwork is planned in Jordan, and an important project partner (CSS) is
based there. However, as already stated, no personal data will be shared
between partners. In WP4 data analysis partners will transfer databases
containing numerical data, but this includes no data that could be linked to
any individual. We will also be transferring anonymised and translated
transcripts of the qualitative data from the focus groups to CSS in order to
be able to develop the coding and perform the cross-site analysis of this
data. Personal data will be retained the research partner that collects it and
not shared with any other partner. There will be no transfers of personal data
from fieldwork between the EU and non-EU countries.

</td> </tr>  
<tr>  
<td>

Long term preservation

</td>  
<td>

Partners will keep all project data for a period of 5 years after the end of
the project in order to comply with possible reviews or audits. After this
point – unless an internal policy or local institutional or regional/national
law or best-practice recommends or requires otherwise – all personal data
gathered during the project will be destroyed. Non-personal data may be
retained by the partners (but the main project datasets will be available via
the Zenodo repository, in accordance with the positions set out above
(sections 3 & 4)).

</td> </tr> </table>

6\. Ethical aspects

This section deals with ethical aspects of the data management practices
discussed above. A full discussion of ethics management more generally – i.e.
covering all aspects of research ethics in the project, not only those
concerning data management – is included in section 8, which presents the
FOCUS project _Ethics Management Plan_ (EMP).

###  6.1 Personal data processing: risk assessment

Processing of personal data will take place in the project as described in
Table 5, below. Please note that a Data Protection Impact Assessment specific
to the planned fieldwork has been conducted. This is reported in _Section 7.1_
.

**Table 5:** Risk assessment for personal data processed in the scope of
FOCUS.  
  
<table>  
<tr>  
<th>

**WP**

</th>  
<th>

**Description**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

**Data subject:** Members of the EAB and Advisory Board.

**Data type:** Name, contact details, and some biographical information (about
career history).

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To manage the boards and arrange travel for attendance at
meetings.

**Ethics manager comments:** Small amount of non-sensitive data, processed
with the data subjects’ explicit consent.

**Risk assessment:** **Low risk.**

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

**Data subject:** Consortium members.

**Data type:** Name, contact details, professional opinions relative to the
project.

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To carry out the project effectively.

**Ethics manager comments:** Relatively small amount of non-sensitive data,
processed in the course of their contractual employment.

**Risk assessment:** **Low risk.**

</td> </tr>  
<tr>  
<td>

3

</td>  
<td>

**Data subject:** Stakeholders being interviewed or attending workshops.

**Data type:** Name, contact details, and some biographical information (about
career history).

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To get valuable advice, feedback, and perspectives on issues
pertinent to the development of the Toolbox.

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

**Ethics manager comments:** Small amount of non-sensitive data, processed
with the data subjects’ explicit consent.

**Risk assessment:** **Low risk.**

</th> </tr>  
<tr>  
<td>

4

</td>  
<td>

**Data subject:** Members of the EAB and Advisory Board.

**Data type:** Professional opinions as expressed in a workshop.

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To get valuable advice and feedback on the development of the
fieldwork methodology.

**Ethics manager comments:** Small amount of non-sensitive data, processed
with the data subjects’ explicit consent.

**Risk assessment:** **Low risk.**

</td> </tr>  
<tr>  
<td>

5

</td>  
<td>

**Data subject:** Fieldwork participants (refugees and host communities).

**Data type:** Name, contact details, feedback on the proposed fieldwork
survey procedure.

**Volume of data:** Low (n=30 per site; total n=120)

**Sensitivity of data:** Low

**Purpose:** To validate the fieldwork methodology.

**Ethics manager comments:** Small amount of data, processed with the data
subjects’ explicit consent. Note that survey responses are not collected.

**Risk assessment:** **Low risk.**

</td> </tr>  
<tr>  
<td>

6

</td>  
<td>

**Data subject:** Fieldwork participants (survey) (refugees and host
communities).

**Data type:** Name, contact details, responses to the fieldwork survey
(includes small amount of sensitive data).

**Volume of data:** Medium (n=1200 per 3 sites and n=800 in 1 site; total
n=4,400)

**Sensitivity of data:** Some survey questions could directly or indirectly
reveal special categories of data, including ethnic or racial origin,
religion, political opinions, health.

**Purpose:** Main fieldwork of project: to better understand refugee/host-
community integration.

**Ethics manager comments:** A medium amount of data, processed with the data
subjects’ explicit consent. Some sensitive data will be collected. A data
protection impact assessment is required (see _Section 7.1_ below). Ethics
approvals for the research are required.

**Risk assessment:** **Medium risk (pending ethics approvals from competent
research ethics committees).**

</td> </tr>  
<tr>  
<td>

7

</td>  
<td>

**Data subject:** Fieldwork participants (focus groups) (refugees and host
communities).

**Data type:** Name, contact details, feedback from focus group discussions.
**Volume of data:** medium (4-5 focus groups per site, 16-20 in total)
**Sensitivity of data:** Low.

**Purpose:** Main fieldwork of project: to better understand refugee/host-
community integration.

**Ethics manager comments:** A medium amount of data, processed with the data
subjects’ explicit consent. Sensitive data is not intended to be collected,
but it may be volunteered by participants. This activity is included in the
data protection impact

</td> </tr>  
<tr>  
<td>

</td>  
<td>

assessment mentioned in line 6. Ethics approvals for fieldwork (line 6) also
cover this activity.

**Risk assessment:** **Low risk (pending ethics approvals from competent
research ethics committees).**

</td> </tr>  
<tr>  
<td>

8

</td>  
<td>

**Data subject:** Stakeholders attending a Toolbox training seminar.

**Data type:** Name, contact details, and some biographical information (about
career history), opinions on the Toolbox.

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To get valuable advice, feedback, and perspectives on issues
pertinent to the development of the Toolbox.

**Ethics manager comments:** Small amount of non-sensitive data, processed
with the data subjects’ explicit consent.

**Risk assessment:** **Low risk.**

</td> </tr>  
<tr>  
<td>

9

</td>  
<td>

**Data subject:** Pilot-testing participants (end-users & stakeholders).

**Data type:** Name, contact details, some background biographical
information, responses to the pilot-test survey questions (details to be
confirmed).

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To get valuable advice, feedback, and perspectives on issues
pertinent to the development of the Toolbox.

**Ethics manager comments:** A low volume of non-sensitive data. Data will be
processed with the data subjects’ explicit consent. Note that procedures for
gathering consent are yet to be confirmed. Data to be collected is not yet
confirmed.

**Risk assessment:** **Low risk (but to be confirmed).**

</td> </tr>  
<tr>  
<td>

10

</td>  
<td>

**Data subject:** Network of Host Communities members.

**Data type:** Name, contact details, contributions to the online network,
associated metadata generated by their online activity.

**Volume of data:** Low.

**Sensitivity of data:** Low.

**Purpose:** To develop a strong, active, sustainable network of stakeholders.

**Ethics manager comments:** Low volume of non-sensitive data. Data will be
processed with the data subjects’ explicit consent.

**Risk assessment:** **Low risk.**

</td> </tr> </table>

Note that where personal data is processed on the basis of data subject
consent, that consent will be clearly documented, in accordance with the
standards demanded by Article 7 of the GDPR (“Conditions for consent”). Where
consent for personal data processing is collected along with consent to
participation in a research activity (e.g. fieldwork), the two consents will
be collected and recorded separately, in accordance with paragraph 2 of
Article 7 of the GDPR.  13

A data protection impact assessment for the fieldwork data collection is
presented in _Section_

_7.1_ below.

Measures to ensure that personal data is processed in compliance with the GDPR
are discussed in _section 8.3_ of the Ethics Management Plan.

No personal data will be included in any dataset or deliverable uploaded to
Zenodo, nor in any article published in the course of the project.

(Again, please note that a full discussion of all ethics issues in the project
is presented in _section 8_ below, Ethics Management Plan.)

13  “If the data subject’s consent is given in the context of a written
declaration which also concerns other matters, the request for consent shall
be presented in a manner which is clearly distinguishable from the other
matters, in an intelligible and easily accessible form, using clear and plain
language” (GDPR, Art.

7.2).

  7. Other Issues 

  

  

This section contains two subsections. The first presents a **data protection
impact assessment (DPIA)** for the fieldwork data collection. The second
presents the designated contact points in respect of ethics and data
management for each consortium partner.

The consortium is not aware of any other issues that are not addressed either
above in the DMP, here in the DPIA, or below in the _EMP_ .

7.1 Fieldwork data protection impact assessment (DPIA)

**DATA PROTECTION IMPACT ASSESSMENT**

**July 2019**

###  Introduction: why conduct a DPIA in FOCUS

Article 35 of GDPR establishes the obligation of data controllers to conduct a
Data Protection Impact Assessment (DPIA) when a proposal for processing of
personal data is likely to result in a high risk to the fundamental rights and
freedoms of individuals. The DPIA is a procedure whereby controllers identify
the data protection risks that arise when developing new products and services
or when undertaking any new activities in the course of a project that involve
the processing of personal data. The early identification of the risks
subsequently allows data controllers to take appropriate measures to prevent
or minimise the impact of any identified risks.

In order to determine the level of risk that a particular project carries,
controllers need to conduct a threshold assessment – that is, a preliminary
screening for factors signalling any potential for a widespread or serious
impact on individuals. As described by the UK’s Information Commissioner’s
Officer (ICO):

_the important point here is not whether the processing is actually high risk
or likely to result in harm – that is the job of the DPIA itself to assess in
detail. Instead, the question is a more high-level screening test: are there
features which point to the potential for high risk? You are screening for any
red flags which indicate that you need to do a DPIA to look at the risk
(including the likelihood and severity of potential harm) in more detail._ 13

Article 35(3) GDPR requires data controllers to conduct a DPIA, irrespective
of the result of any threshold assessment, when:

  1. a systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person; 

  

  2. processing on a large scale of special categories of data referred to in Article 9(1), or of personal data relating to criminal convictions and offences referred to in Article 10. 

  

  3. a systematic monitoring of a publicly accessible area on a large scale. 

  

  

These conditions are not present in the FOCUS fieldwork.  14  However, the
Article 29 Data Protection Working Party (WP29) has noted the list contained
in Article 35(3) GDPR is not intended to be exhaustive and that there may be
other “high risk” processing operations that should therefore be subjected to
DPIAs.  15  In 2016, the WP29 issued guidelines on the correct interpretation
of Article 35 GDPR, which included a set of the criteria to be used in
determining where it is likely that a processing operation would entail a high
risk to the fundamental rights of data subjects. These criteria have been
endorsed by the European Data Protection Board (EDPB) and the European Data
Protection Supervisor (EDPS) through the adoption of a Decision on 16 July
2019.  16  This Decision contains a template that data controllers must review
to determine if their operations merit a DPIA. Article 3 of the EDPS’ decision
states that “[w]hen assessing whether their planned processing operations
trigger the obligation to conduct a DPIA […] the controller shall use the
template in Annex 1 to this Decision to conduct a threshold assessment.”

The nine criteria which may act as indicators of likely high-risk processing
are the following:

  1. Systematic and extensive evaluation of personal aspects or scoring, including profiling and predicting. 

  

  2. Automated decision making with legal or similar significant effect. 

  

  3. Systematic monitoring. 

  

  4. **Sensitive data or data of a highly personal nature.**

  

  5. Data processed on a large scale, whether based on number of people concerned and/or amount of data processed about each of them and/or permanence and/or geographical coverage. 

  

  6. Datasets matched or combined from different data processing operations performed for different purposes and/or by different data controllers in a way that would exceed the reasonable expectations of the data subject. 

  

  7. **Data concerning vulnerable data subjects.**

  

  8. Innovative use or applying technological or organisational solutions that can involve novel forms of data collection and usage. 

  

  9. Preventing data subjects from exercising a right or using a service or a contract 

  

  

The idea of the template is that if two or more of the criteria in the list
apply, the controller should carry out a DPIA.  17  If the controller
considers that, in the specific case at hand, although more than one criterion
in the template is applicable the risks are nonetheless not high, they may
omit to carry out a DPIA. In such a case, the controller shall clearly
document and justify that decision.  18  On the other hand, the ICO advises
that in case of any doubt, or if only one factor is present, a DPIA _should_
be conducted to ensure compliance and encourage best practice.  19

The FOCUS fieldwork includes collection of sensitive data (religious
background and opinions, some mental health information) from host communities
and refugees in order to analyse how different factors influence the level of
integration of refugees and the perception of and attitudes towards them in
host communities. Moreover, since refugees are considered a _vulnerable group_
under the GDPR,  20  _prima facie_ the project fulfils two of the criteria
listed by the EDPS’ threshold assessment, specifically number 4 and 7 (in
bold). Thus, although we do not feel the proposed data processing is high
risk, we nonetheless follow the advice of both the EDPS and ICO by conducting
a DPIA at this stage in order to identify potential risks to the fundamental
rights and freedoms of research participants in FOCUS.

The GDPR describes the minimum structure of a DPIA  21  :

_The assessment shall contain at least:_

  1. _a systematic description of the envisaged processing operations and the purposes of the processing, including, where applicable, the legitimate interest pursued by the controller;_

  

  2. _an assessment of the necessity and proportionality of the processing operations in relation to the purposes;_

  

  3. _an assessment of the risks to the rights and freedoms of data subjects referred to in paragraph 1; and_

  

  4. _the measures envisaged to address the risks, including safeguards, security measures and mechanisms to ensure the protection of personal data and to demonstrate compliance with this Regulation taking into account the rights and legitimate interests of data subjects and other persons concerned._ 22 

  

  

To meet, and then go beyond, these minimum standards, we follow the WP29
approach to DPIA. On this approach, a DPIA is not a one-off event, but an
ongoing process.

Description of

processing

Assessment of

necessity and

proportionality

Measures already

envisaged

Assessment of the

risks to rights and

freedoms

Measures

envisaged to

adress the risks

Documentation

Monitoring

**Data Protection Impact Assessment**

**Cycle**

The FOCUS DPIA is conducted by AND Consulting Group (AND), with input
collected from the other consortium partners. It relates specifically to Work
Packages 3 and 4 of the project, in which fieldwork (survey and focus groups)
will be conducted with refugees from Syria and with people from host
communities in Jordan, Croatia, Germany, and Sweden in which refugees from
Syria have settled.

###  Step 1: Description of the processing

####  High-level description  23

The intention is to conduct academic fieldwork, within the scope of an H2020
project, to identify factors affecting the integration of refugees from Syria
and people from the host communities in which they now live. The fieldwork
involves two streams of data collection: a survey, and focus groups. These
will be conducted with research participants (i.e. refugees from Syria and
members of host communities) in four countries: Sweden, Germany, Croatia, and
Jordan. The data collected from each of these activities will be processed by
academic institutions in each country (which are FOCUS consortium partners):

  * Sweden – MAU 

  

  * Germany – HU/Charite 

  

  * Croatia – FFZG 

  

  * Jordan – CSS 

  

These partners are the data controllers, responsible for their own data
collection and processing in their respective countries. Each partner will
have, in effect, two classes of data: (1) responses to the survey or focus
group; (2) copies of informed consent forms.  24  Each partner will
pseudonymise the data of class 1, using standard methods (described further
below). Data of class 2 will be stored securely for a period of not more than
10 years. This period is based on institutional requirements. This data will
not be further processed or shared at all unless either: (i) the data subject
requests that their data be withdrawn from the study or otherwise exercises
their subject access rights (as per GDPR Chapter 3); or (ii) the institution
is subject to a legal requirement requiring processing of this data (e.g. some
sort of project review or audit).

The pseudonymised research data will be collated by CSS, who are also
responsible for the data analysis. The data that is sent to CSS is, from the
perspective of CSS, anonymous. CSS does not have the capacity to re-identify
any data subject from the datasets provided by MAU, HU/Charite, or FFZG. Thus,
while it must be noted, that data collected by MAU, HU/Charite, and FFZG will
be transferred outside the EU/EEA, this data is, from the respective
perspectives of MAU, HU/Charite, and FFZG _pseudonymous_ and, from the
perspective of CSS (and anyone else), _anonymous_ .

All data analysis is conducted on the entire dataset. This means that
individual records will not be examined and that individual research
participants will not be identifiable from the combined dataset. The data will
be used to produce insights into factors that affect the integration of the
two target groups. Research outputs based on this data will contain no
personal data whatsoever. The dataset will be made public, but no personal
data will be made public (i.e. it will not be possible to identify any data
subject from the dataset).

The only way in which individual data subjects’ responses can be linked to
their identity is with the use of a unique code, known only to the data
subject and to the partner that collected their data. This is necessary in
order to allow data subjects to request that their data be removed from the
study. The data enabling the linking of a survey response with an identifiable
individual (i.e. the Class 1 data, as defined above) will be stored for no
longer than 10 years. At this point, the data will be irrevocably destroyed.
Publicly available datasets will be stored indefinitely (but, as mentioned,
they contain no personal data whatsoever).

####  Necessity of a DPIA

The rationale for conducting a DPIA in FOCUS concerning the fieldwork is fully
described in the introduction to this section.

A further note is necessary concerning the data collection and processing
taking place in Jordan, which is in neither the EU nor the EEA. The GDPR
applies “ _to the processing of personal data in the context of the activities
of an establishment of a controller or a processor in the Union, regardless of
whether the processing takes place in the Union or not_ ”  25  and “ _to the
processing of personal data of data subjects who are in the Union by a
controller or processor not established in the Union_ ”  26  . It is
questionable whether personal data processing by CSS in Jordan of Jordanian
residents is subject to the GDPR. Regardless, it was agreed in FOCUS, even at
the stage of writing the project proposal, that we would apply the standards
of the GDPR to all project activities, irrespective of where they take place
and who the data subjects are.

What data is collected and processed?

Three kinds of data are collected and processed:

  1. Survey responses 

  

  2. Focus group contributions 

  

  3. Personal details for purposes of recruitment and informed consent 

  

  

#####  Survey responses

There are two surveys. One is addressed to refugees from Syria (henceforth
‘refugees’); one is addressed to members of communities hosting refugees in
Sweden, Germany, Croatia, and Jordan (henceforth ‘host community members’).
The two surveys differ somewhat on the specific questions asked, but the same
surveys are used in each country for refugees and host community members.

The procedure for conducting the surveys is such that, even though the survey
itself does not include the subject’s name or other directly identifying
information, the subject can be identified by drawing a connection between a
unique code on each individual survey response and the same code included on
the informed consent form that the participant completes. The possibility of
this connection is designed into the survey procedure in order to allow that
research subjects are able to withdraw their data from the study even after
they have completed the survey. From a purely data protection perspective, it
may have been desirable to avoid this possibility. However, from a research
ethics perspective, it is very desirable to allow research participants to be
able to withdraw their data. Having balanced the risk of reidentification –
which we consider to be low likelihood – against the positive impact of
enabling withdrawal of data, we concluded that it was, overall, better for
data subjects that we make this possible.

#####  Focus group contributions

There will be two forms of focus group: one with refugees, one with host
community members. The target topic is the overall integration of refugees
from Syria in the relevant country. The discussion will be directed so as to
elicit participants’ perceptions of the process of integration in their
country. As such, it will cover an array of issues ranging from labour market
integration to the extent and nature of interaction between host community
members and refugees.

As with the surveys, the focus group procedure is designed in such a way that
participants’ contributions are not wholly anonymous (though they are
pseudonymised) in order that the participants can withdraw their contributions
after the event, if they so wish.

#####  Personal details for purposes of recruitment and informed consent

Recruitment for the surveys is by random walk technique or random sampling.
This does not entail additional processing of personal data. Recruitment for
focus groups is by snowballing methods. In order to facilitate participation,
some contact details (name, email, telephone number) are required.

There is a robust informed consent procedure for the fieldwork. Participants
must provide their name (and a signature, unless an oral consent procedure is
used). The participant’s name will be associated with a unique code number.
The code is included on both the informed consent form (thus, alongside the
participant’s name) and the participant’s survey response. The point of this
code is to provide a link between the participant’s identity and their survey
responses. In the absence of the code, there is nothing in the survey to link
a particular response with a particular person: with the code, a particular
survey can be linked to a particular person. Focus group participants will
have their contributions pseudonymised during the transcription process (e.g.
instead of “John Smith” use “Participant 1”). Researchers will have a record
of which participant is given which number. Again, the point of this is to
provide a link between the participant’s identity and their contributions.

####  Selection of participants/data subjects

The data subjects are refugees from Syria settled in the respective countries,
or members of host communities in the respective countries. Participants are
selected only on the basis of being a member of one of these groups. They will
be excluded from participation on the basis of either _age_ (only adults
involved) or _asylum status_ (people whose application for asylum is ongoing,
or who have been refused, are not eligible to take part in the study). The
researchers have no pre-existing relationship with the data subjects.

Participation is completely voluntary. It is made clear to potential
participants, via an information sheet, that they are in no way obliged to
take part, that they receive no special benefit from taking part except a
thank you gift of no more than 20€ or equivalent such as shopping coupons
(agreed by the experts in the consortium to be appropriate), and that they may
withdraw from the process at any point (including after their survey, at which
point they may still withdraw their data).  27  The informed consent process
makes absolutely clear to the potential participants what their participation
involves and how their data will be used. Since no further processing of the
data is to be conducted, the data will not be processed in ways that the
participants might not expect.

####  Purpose

The overall purpose of the processing is to better understand the nature of,
and factors affecting, the integration of refuges from Syria in host
communities in Sweden, Germany, Croatia, and Jordan. From this, the consortium
will extrapolate views concerning the nature of, and factors affecting, the
integration of refuges from Syria in host communities in general.

The aggregated dataset will be made publicly available (in anonymised form).
The purpose of this is to enable other researchers to use the data, thereby
maximising its potential to provide value to society. This is in line with the
requirements of the European Commission’s approach to the use of research data
collected with the use of EU public funding. (This is outside the scope of the
GDPR, as the data is anonymous, but it is here noted as a matter of full
transparency.)

####  Legal basis

The legal basis for the processing of personal data in FOCUS fieldwork is
_consent_ , under

GDPR, Article 6(1)(a). This implies the following requirements, derived from
GDPR, Article 7 ( _Conditions for consent_ ).

  1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 

  

  

_Each partner is responsible for being able to demonstrate that the data
subject consented to participate. This is achieved by the use of informed
consent forms, stored (in physical format) by the respective partners. Where
an oral consent procedure is used, the forms will be retained (not signed by
the subject), but signed by the person who witnessed the giving of consent._

  2. If the data subject’s consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. 

  

  

_The informed consent forms are specific to the survey or focus group (there
are separate information sheets for each activity) and do not address any
other activities. The informed consent forms cover research ethics as well as
data protection. However, the participant must check a specific box to
indicate their consent to the data processing aspects of the research._

  3. The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent. 

  

  

_As mentioned above, the activities are explicitly designed to ensure that
consent can be withdrawn and the subject’s data can be removed from the study.
The information sheets that accompany the informed consent form make clear
that the subject has the right to withdraw, even after the activity is
finished. Although the process for withdrawing takes longer than the process
for consenting, it is not significantly more difficult._

  4. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract. 

  

  

_The researcher collecting the informed consent is responsible for assessing
whether the consent is freely given. Nothing else is conditional on the
subject’s consent._

####  Processing of special categories of personal data

GDPR Article 9 in principle prohibits the processing of certain categories of
data, unless certain conditions obtain.

_Processing of personal data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade union membership, and
the processing of genetic data, biometric data for the purpose of uniquely
identifying a natural person, data concerning health or data concerning a
natural person’s sex life or sexual orientation shall be prohibited_ .  28

In the FOCUS fieldwork:

  * the informed consent and recruitment processes **do not** involve processing of special categories of personal data; 

  

  * the focus groups **do not** involve processing of special categories of personal data (however, it is possible that such data may be volunteered by a participant). 

  

  * the surveys **_do_ ** involve processing of special categories of personal data. 

  

The surveys **directly ask for** information concerning:

  * **health** (‘psychological wellbeing’, ‘access to mental health services’, ‘physical wellbeing’) 

  

  * **religion/ethnic origin** (‘what is your religion?’, ‘how often do you attend religious meetings?’, etc.) 

  

  * **political opinions** (‘what is your political orientation?’, etc.) 

  

The surveys ask for information that could be **indirectly suggestive** of:

  * **ethnic origin** (‘where was your spouse/partner born?’; 

  

  * **trade union membership** (‘what is your current profession?’, etc.) 

  

The surveys also ask for data that **could be sensitive** , even though it is
not included as a special category of data:

  * **asylum status**

  

  * **‘what are your net earnings…?’**

  

  * **receipt of government welfare**

  

With regard to these aspects of the proposed processing, we rely on GDPR
Article 9(2)(a): _Paragraph 1 shall not apply if one of the following
applies:_

_(a) the data subject has given explicit consent to the processing of those
personal data for one or more specified purposes, except where Union or Member
State law provide that the prohibition referred to in paragraph 1 may not be
lifted by the data subject;_

As described in the _Legal basis_ section above, we have taken steps to ensure
that data subjects give explicit consent to the personal data processing. The
information sheet makes clear that the survey asks questions that reveal
information about health, religious views, ethnic origin, and political
opinions.

####  Involvement of vulnerable groups

Vulnerability may derive from a number of factors. For example, the CIOMS
guidelines on Health-related Research Involving Humans list the following
potentially vulnerable groups or factors:  29

  * capacity to consent; 

  

  * individuals in hierarchical relationships; 

  

  * institutionalised persons; 

  

  * women; 

  

  * people receiving welfare benefits or social assistance and other poor people and the unemployed; 

  

  * people who perceive participation as the only means of accessing medical care; • some ethnic and racial minorities; 

  

  * homeless persons, nomads, refugees or displaced persons; 

  

  * people living with disabilities; people with incurable or stigmatized conditions or diseases; 

  

  * people faced with physical frailty, for example because of age and co-morbidities; 

  

  * individuals who are politically powerless; 

  

  * members of communities unfamiliar with modern medical concepts; 

  

  * in some contexts, vulnerability might be related to gender, sexuality and age. 

  

A further difficulty in ensuring adequate protection of the rights and
interests of potentially vulnerable people, is that it can be difficult to
assess whether someone is (a) a member of vulnerable-group-category, and (b)
whether their membership of that vulnerable-groupcategory _in fact_ makes them
vulnerable in the specific case.  30

In FOCUS, the most obvious factor affecting potential vulnerability concerns
people who are refugees from Syria, as these people are directly targeted in
sampling. But other factors from the list above should be considered.  
  
<table>  
<tr>  
<th>

**Directly applicable**

</th>  
<th>

**Indirectly applicable**

</th>  
<th>

**Not applicable**

</th> </tr>  
<tr>  
<td>

Homeless persons, nomads, refugees or displaced persons

</td>  
<td>

Women

</td>  
<td>

Capacity to consent

</td> </tr> </table>  
<table>  
<tr>  
<th>

_\- Refugees from Syria are a target population._

</th>  
<th>

\- _Women will certainly be included but should not be vulnerable as such._

</th>  
<th>

\- _Capacity to consent is a condition of participation._

</th> </tr>  
<tr>  
<td>

</td>  
<td>

People receiving welfare benefits or social assistance and other poor people
and the unemployed

\- _Refugees from Syria may be in receipt of welfare._

</td>  
<td>

Individuals in hierarchical relationships \- _Not likely._

</td> </tr>  
<tr>  
<td>

</td>  
<td>

People who perceive

participation as the only means of accessing medical care

\- _Since access to healthcare is an issue in integration, involvement of such
people cannot be excluded._

</td>  
<td>

Institutionalised persons - _Not likely._

</td> </tr>  
<tr>  
<td>

</td>  
<td>

Some ethnic and racial minorities

\- _Refugees from Syria are typically ethnic/racial minorities in host
communities_

</td>  
<td>

People living with disabilities; people with incurable or stigmatized
conditions or diseases

\- _No more likely than in any other research._

</td> </tr>  
<tr>  
<td>

</td>  
<td>

Individuals who are politically powerless

\- _Refugees from Syria are arguably less well represented politically._

</td>  
<td>

People faced with physical frailty, for example because of age and co-
morbidities

\- _No more likely than in any other research._

</td> </tr>  
<tr>  
<td>

</td>  
<td>

</td>  
<td>

Members of communities unfamiliar with modern medical concepts

\- _No more likely than in any other research._

</td> </tr>  
<tr>  
<td>

</td>  
<td>

</td>  
<td>

In some contexts, vulnerability might be related to gender, sexuality and age

\- _No more likely than in any other research._

</td> </tr> </table>

These factors will be reflected in the risk analysis conducted at Steps 4 and
5.

###  Step 2: Assessment of necessity and proportionality

####  Necessity

The proposed personal data processing is a necessary step relative to the
stated objective of the FOCUS research project. Here we demonstrate this by
presenting a recapitulation of the overall objectives of the project, as well
as the specific goals of the fieldwork.

The overall goal of the FOCUS project is to “ _increase understanding of, and
provide effective and evidence-based solutions for, the challenges of forced
migration within host communities and thereby contribute to increased
tolerance, peaceful coexistence, and reduced radicalization across Europe and
in the Middle East_ ”. FOCUS also “ _undertakes an ambitious programme of
engagement with policy makers, end-users, host communities, refugees and other
stakeholders_ ”. This is in order to “ _ensure that FOCUS research and
solutions are acceptable and useful for policy makers, while meeting the needs
of end-user organisations and ultimately refugees and host communities_ ”.  31

The fieldwork component of the project can be seen as necessary and integral
to the pursuit of these goals. For it is the fieldwork which enables the FOCUS
researchers to gain first-hand insight into the “ _the challenges of forced
migration within host communities_ ”. There is no other means of gathering
this information which would be both as effective and involve processing less
personal data. The insights gained from this research serves as the basis for
the development of evidence-based solutions to promote integration.

The overall project, and the fieldwork in particular, is thus directed towards
a legitimate, societally desirable goal, which is in the public interest,
supported by public funding from the European Commission.

**The survey is a necessary component of the fieldwork** . Surveying is the
most efficient and effective means of gathering feedback from a statistically
significant number of participants. The survey has been developed through a
detailed process. FOCUS WP2 provided key background information on the socio-
economic and socio-psychological integration of refugees and host communities,
as well as analysis of integration policies, tools, and asylum migration
patterns. WP3 used the outcomes of WP2 to develop indicators of integration
and specific research questions. The survey has been designed to target these
indicators and research questions. The highly experienced experts in this
field have leveraged their experience and expertise to ensure that (a) the
survey questions directly and fully address the stated research questions and
that no questions are included which cannot be linked to a specific research
goal.

The **focus groups are a necessary complement to the survey** . The same
topics, indicators, and research questions as are addressed in the survey are
also addressed in the focus groups. But the focus groups provide qualitative
data. It is very valuable to have quantitative data from the survey and
qualitative data from the focus groups. Again, the focus groups have been
designed and planned by experienced experts and will be moderated to ensure
they keep on-topic, not gathering unnecessary personal data from participants.

The **processing of personal details for purposes of recruitment is
necessary** to make the focus groups possible. The **processing of personal
data via informed consent forms is a basic requirement** of good research
ethics.

####  Proportionality

Are these processing activities proportional? Yes. The FOCUS project pursues a
legitimate, societally desirable goal in the public interest, the fieldwork is
a necessary component of the project, and the fieldwork is designed to collect
the minimum viable amount of data from participants. Other things being equal,
and pending the risk analysis presented below, the proposed processing is
necessary and proportional in pursuit of a legitimate goal. Below we support
this assessment by outlining the measures to ensure good practice in data
protection.

###  Step 3: Measures already envisaged

####  Data minimisation

The surveys and focus groups have been developed, over an extended period of
months, by senior, highly experienced experts in this field. They have
leveraged all their experience and expertise to ensure that (a) the study
design is geared towards explicitly stated research questions, and (b) that
the content of the surveys and focus groups involves the collection of enough
data to fully address the research questions, but no more than is required.
The number of data subjects will be 4,400 across the four research sites.
These numbers have been agreed as the smallest amount that can reliably
produce the desired results at the necessary level of confidence.

####  Preventing function creep

The purpose of the personal data processing is set out above. To ensure that
these purposes do not ‘creep’, i.e. that the consortium does not use the data
for other, non-stated, purposes, it has been ensured that the data is
pseudonymised (relative to the partner who collected it) and anonymised
(relative to everyone else) prior to aggregation and analysis. The aggregated,
anonymised dataset will be made publicly available at the end of the project.
This means that there is actually little point in using personal data for
unstated purposes as all research goals can be achieved with the anonymised
dataset anyway.

####  Data retention

The survey and focus group contributions are pseudonymised at, or very shortly
after, the point of collection. The nature of the pseudonymisation is strong.
Surveys can only be reidentified using the code that is kept securely by the
relevant partner. Data is never shared in non-pseudonymous form. Indeed, when
shared, the data is effectively anonymous because no one except the party that
collected it has access to the code. The only data that that directly
identifies the data subject is the informed consent form and the contact
details that are required for recruitment. Contact details will be deleted
after the focus groups have been completed. (Note also that the recordings of
the focus groups will be destroyed as soon as the transcription has been
completed.) That leaves only the informed consent forms. These are retained
for not more than 10 years, in line with institutional requirements.

####  Security and data sharing

Each partner is responsible for ensuring the security of the data they
collect. As established academic institutions, they have the organisational
capacity and expertise to ensure data security. Each partner will follow the
data security policies prescribed by their own organisation, with the
provision that the following minimum standards will be respected.

  * _Digital data backups:_ All survey responses and transcriptions of focus group discussions will be backed up on at least one physically distinct medium (e.g. on a separate server, external hard drive, etc.). Recordings are on devices that are not connected to the Internet. 

  

  * _Physical data backups:_ All informed consent forms will be stored in a secure environment, in a locked drawer or equivalent. No digital backups or photocopies will be made. 

  

  * _Access control_ : All personal data from the fieldwork will be subject to strict access control. Only persons engaged in the project by the relevant partner will be given access to fieldwork data, and then only with the permission of an authorised team member of the relevant partner. Once made publicly available, the anonymous dataset will not be subject to access control (but note that this data will not include any personal data). 

  

  * _Data transfers (general)_ : There will be no sharing of personal data from fieldwork between partners within EU Member States (any such data will be anonymised prior to transfer and then transferred in encrypted format). 

  

  * _Data transfers (outside EU)_ : As stated, no personal data will be shared between partners. Data transferred to Jordan will be effectively anonymous (it will be personal data only to the research partner that collected it, for whom it will be pseudonymous). 

  

####  Accountability

Each partner responsible for collecting data in the fieldwork is, as data
controller, responsible for demonstrating their compliance with the GDPR. They
are also responsible for ensuring the good practice and compliance of any data
processors working on their behalf.

####  Transparency

Data subjects go through an informed consent process prior to participation
and data collection. This process provides them with information about the
project and about their involvement in it. They will be informed of the
purposes and nature of the data processing, as well as that some special
categories of personal data will be processed. They will also be informed
about the pseudonymisation of their data and given assurances that their data
is not shared except in anonymised form. Full details of the measures to
protect their personal data are provided on a dedicated page on the project
website, to which they are provided the links.

####  Data subjects’ rights

Data subject’s rights are set out in GDPR Chapter 3. Participants are provided
with information on how to exercise their rights, by contacting the relevant
data protection officer or contact point, on the informed consent form that
they sign when they agree to participate in the research. They are also
addressed to the project website, which contains privacy notices specifically
for the fieldwork. These notices provide full details of all measures taken to
protect their personal data and full instructions on how to exercise their
rights.

####  Compliance of data processors

Each data controller (MAU, HU/Charite, FFZG, CSS) is responsible for ensuring
the compliance of any data processors that they engage (as per GDPR Article
28). Data processors may be employed, via contract, to conduct the survey
fieldwork. People conducting the fieldwork are given training via a manual,
developed within the scope of WP3. This provides guidance on best practice for
the survey.

####  Safeguarding international transfers

Data is pseudonymised prior to transfer. Since only the data controllers who
collected the data have the codes that link particular survey responses to
particular individuals, the data is effectively anonymous to any other party,
including the intended recipients (CSS). In effect then, the data is
transferred in an anonymous state. All data transfer will also be encrypted
for additional security.

####  Measures to minimise impact of processing special categories of data

It was established above that the survey collects the following ‘special
categories’ of data and potentially sensitive data.  
  
<table>  
<tr>  
<th>

**Category directly asked about**

</th>  
<th>

**Specifically**

</th> </tr>  
<tr>  
<td>

Health

</td>  
<td>

‘Psychological wellbeing’, ‘access to mental health services’, ‘physical
wellbeing’

</td> </tr>  
<tr>  
<td>

Religion/ethnic origin

</td>  
<td>

‘What is your religion?’, ‘how often do you attend religious meetings?’, etc.

</td> </tr>  
<tr>  
<td>

Political opinions

</td>  
<td>

‘What is your political orientation?’, etc.

</td> </tr>  
<tr>  
<td>

**Category indirectly asked about**

</td>  
<td>

**Specifically**

</td> </tr>  
<tr>  
<td>

Ethnic origin

</td>  
<td>

‘Where was your spouse/partner born?’

</td> </tr>  
<tr>  
<td>

Trade union membership

</td>  
<td>

‘What is your current profession?’, etc.

</td> </tr>  
<tr>  
<td>

**Other potentially sensitive data / topics**

</td> </tr>  
<tr>  
<td>

Asylum status

</td> </tr>  
<tr>  
<td>

‘What are your net earnings…?’

</td> </tr>  
<tr>  
<td>

Receipt of government welfare

</td> </tr> </table>

Although this data is sensitive, the impact of processing it is very small.
First, the data is very unlikely to lead to any kind of discrimination because
it will not be shared with any partners who are not engaged in the project and
committed to its positive societal objectives. Second, the data is
pseudonymised (relative to the party that collects it) and anonymised
(relative to the parties to whom it is transferred). When the data is made
public it will be completely anonymous.

####  Measures to minimise impact of involvement on vulnerable groups

Refugees from Syria are a target population of the fieldwork. There are two
main ways in which people from this group could be negatively affected by the
data collection and processing.

Firstly, in conducting the research (survey or focus group), they could be led
to revisit painful episodes in their past or present circumstances, leading to
discomfort or pain. In response to this, it should be noted that the research
is not designed to address any such issues. The likelihood of any such
eventualities is very small. Nonetheless, the consortium has taken steps to
deal with any such issues, if they should occur. The information sheet used in
the informed consent process makes clear that if a participant feels
distressed at any time during or after the survey/focus group, they can
contact professionals at the relevant project partner for support. In
addition, there is a short leaflet available to participants which gives
information about what to do if you feel distressed.  32

Secondly, there is, in principle, a very remote possibility that data
collected in the survey or focus groups could, if leaked, have a negative
impact on the data subject. In response to this it should be noted firstly
that the partners take appropriate technical and organisational measures to
ensure against data leaks. Secondly, it is important to note that the worst
effects for people would be if their asylum status was challenged on the basis
of any information revealed by the research. But as against this possibility,
it is important to note that a condition of participation is that the
participant’s asylum status is settled. Thus, the people who are most
vulnerable to this kind of problem are not included among the data subjects.

A general point that should be considered is that the research in FOCUS has
been designed by experts who are experienced in working with refugees and
migrants. They bring all their experience working with such people, and
sensitivity to the risks, to the project.

It has also been identified that some other vulnerable groups are potentially
indirectly impacted by the research. In all cases, the impact on these groups
is secondary to the direct impact that would be brought about by their status
as refugees from Syria. Therefore, the considerations mentioned above in this
subsection apply.

###  Step 4: Assessment of the risks to rights and freedoms

In this section we assess risks to the rights, freedoms, and interests of data
subjects, taking into account the ‘measures already envisaged’ as outlined at
Step 3.  
  
<table>  
<tr>  
<th>

**Risk ID**

</th>  
<th>

**Description**

</th>  
<th>

**Likelihood**

**(1-3) 34  **

</th>  
<th>

**Severity**

**(1-3) 35  **

</th>  
<th>

**Risk Score**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

Lower protections in non-EU/EEA legal frameworks for data protection.

</td>  
<td>

1

</td>  
<td>

2

</td>  
<td>

2

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

Data subjects not fully aware of planned data processing.

</td>  
<td>

1

</td>  
<td>

2

</td>  
<td>

2

</td> </tr>  
<tr>  
<td>

3

</td>  
<td>

Personal data processed for secondary purposes not originally planned or
communicated to data subjects.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr>  
<tr>  
<td>

4

</td>  
<td>

Data collection creep: additional data that is not specifically required for
the assigned purposes is collected.

</td>  
<td>

1

</td>  
<td>

2

</td>  
<td>

2

</td> </tr>  
<tr>  
<td>

5

</td>  
<td>

Data is not accurately recorded.

</td>  
<td>

1

</td>  
<td>

1

</td>  
<td>

1

</td> </tr>  
<tr>  
<td>

6

</td>  
<td>

Pseudonymisation procedures are not effective.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr>  
<tr>  
<td>

7

</td>  
<td>

Data is not securely stored.

</td>  
<td>

1

</td>  
<td>

2

</td>  
<td>

2

</td> </tr>  
<tr>  
<td>

8

</td>  
<td>

Conditions for valid consent under the GDPR are not met.

</td>  
<td>

2

</td>  
<td>

2

</td>  
<td>

4

</td> </tr>  
<tr>  
<td>

9

</td>  
<td>

Collection of special categories of data not appropriately communicated to
data subjects.

</td>  
<td>

2

</td>  
<td>

2

</td>  
<td>

4

</td> </tr>  
<tr>  
<td>

10

</td>  
<td>

Special categories of data not suitably protected.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr>  
<tr>  
<td>

11

</td>  
<td>

Data subjects do not understand how to exercise their rights under GDPR
Chapter 3.

</td>  
<td>

2

</td>  
<td>

2

</td>  
<td>

4

</td> </tr>  
<tr>  
<td>

12

</td>  
<td>

Controllers do not adequately respond to data subjects who exercise their
rights under GDPR Chapter 3.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr>  
<tr>  
<td>

13

</td>  
<td>

Data subjects not able to withdraw their data from the aggregated dataset.

</td>  
<td>

1

</td>  
<td>

2

</td>  
<td>

2

</td> </tr>  
<tr>  
<td>

14

</td>  
<td>

Data subjects can be reidentified from the aggregated dataset.

</td>  
<td>

3

</td>  
<td>

2

</td>  
<td>

6

</td> </tr> </table>

  34. 1 = remote; 2 = possible; 3 = probable. 

  

  35. 1 = minimal; 2 = significant; 3 = severe. 

  

  
  
<table>  
<tr>  
<th>

15

</th>  
<th>

Data processors do not comply with their responsibilities.

</th>  
<th>

1

</th>  
<th>

2

</th>  
<th>

2

</th> </tr>  
<tr>  
<td>

16

</td>  
<td>

Adequate records of data processing not maintained.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr>  
<tr>  
<td>

17

</td>  
<td>

Personal data transferred to third countries.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr>  
<tr>  
<td>

18

</td>  
<td>

Personal or sensitive data that is not strictly relevant to FOCUS’s research
goals or questions may be volunteered during focus groups.

</td>  
<td>

1

</td>  
<td>

2

</td>  
<td>

2

</td> </tr>  
<tr>  
<td>

19

</td>  
<td>

Leaked data about an individual could negatively affect their asylum
application or status.

</td>  
<td>

1

</td>  
<td>

3

</td>  
<td>

3

</td> </tr> </table>

###  Step 5: Measures envisaged to address the risks

In this section we describe mitigations to address the risks identified at
Step 4. In many cases, sufficient mitigations are described at Step 3 – and
hence already taken into account at Step 4 – and so the residual risk is no
lower than the original.  
  
<table>  
<tr>  
<th>

**Risk ID**

</th>  
<th>

**Risk**

**Description**

</th>  
<th>

**Mitigation**

</th>  
<th>

**Effect** (new likelihood / severity score)

</th>  
<th>

**Residual risk score**

(old score in grey)

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

Lower protections in non-EU/EEA legal frameworks

for data protection.

</td>  
<td>

Data processing in Jordan in FOCUS meets GDPR standards. This is a projectwide
policy in FOCUS.

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

Data subjects not fully aware of planned data processing.

</td>  
<td>

Information provided during the informed consent process, with additional
information available on the FOCUS project website (links provided).

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

3

</td>  
<td>

Personal data processed for secondary purposes not originally planned or
communicated to data subjects.

</td>  
<td>

Personal data is pseudonymised (relative to the collecting party) and
effectively anonymised (relative to any other party). Thus if data is re-used
by any party except the collecting party, it is not personal data. For the
collecting party, access to the codes that break the pseudonymisation is
restricted.

Aggregated and anonymised datasets are published, hence there is no real
incentive to use the non-anonymous data.

</td>  
<td>

1 / 3

</td>  
<td>

3 (3)

</td> </tr>  
<tr>  
<td>

4

</td>  
<td>

Data collection creep: additional data that is not specifically required for
the assigned purposes is collected.

</td>  
<td>

The surveys have been designed by a team of experts with clear research
objectives and stated research questions. The surveys are fixed and will be
reviewed by independent institutional research ethics committees.

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

5

</td>  
<td>

Data is not accurately recorded.

</td>  
<td>

Data collection is carried out by professionals with training.

</td>  
<td>

1 / 1

</td>  
<td>

1 (1)

</td> </tr>  
<tr>  
<td>

6

</td>  
<td>

Pseudonymisation procedures are not effective.

</td>  
<td>

Pseudonymisation techniques are standard for the field and have been fully
described. The only link between a survey response and the individual who gave
the data is a single code which is held by only the data subject and the
collecting party on the informed consent form. The informed consent forms are
stored, in

</td>  
<td>

1 / 3

</td>  
<td>

3 (3)

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

physical format in locked drawers (or equivalent). No digital copies are
taken.

</th>  
<th>

</th>  
<th>

</th> </tr>  
<tr>  
<td>

7

</td>  
<td>

Data is not securely stored.

</td>  
<td>

Each data controller is experienced in fieldwork. They have institutional
standards, in addition to the minimum standards that have been defined in
FOCUS. Technical and organisational security measures will be adopted. All
data transfers will (a) involve only aggregated and (effectively anonymised)
data and (b) be secured by encryption.

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

8

</td>  
<td>

Conditions for valid consent under the GDPR are not met.

</td>  
<td>

The informed consent process has been designed to ensure that subjects give a
clear and explicit indication of their consent, that the processing of
sensitive data is made plain to them, that they can consult the full details
of the data protection practices on the website and may do so prior to signing
the informed consent form, and that the consent to data processing is distinct
from the general (research ethics) consent for participating in the study.

In some cases, oral consent may be sought from the participants. This is not
unusual in research of this kind as the requirement to sign a form is, for
reasons of cultural difference, considered more sensitive than it typically
would be in research with culturally European subjects. When consent is given
orally it will be witnessed and recorded by the researcher. In all cases,
whether consent is written or oral, the subject will receive written
information and links to the project website. All resources, from the informed
consent form to the information sheet to the website, will be available in the
language of the host communities

(Swedish, German, Croatian, and Arabic).

</td>  
<td>

1 / 2

</td>  
<td>

2 (4)

</td> </tr>  
<tr>  
<td>

9

</td>  
<td>

Collection of special categories of data not appropriate communicated to data
subjects.

</td>  
<td>

The collection of special categories of data has been carefully assessed –
including categories that are not technically included in the GDPR but are
considered potentially sensitive anyway. Information that this data is to be
collected is communicated to the subjects during the informed consent process.

</td>  
<td>

1 / 2

</td>  
<td>

2 (4)

</td> </tr> </table>  
<table>  
<tr>  
<th>

10

</th>  
<th>

Special categories of data not suitably protected.

</th>  
<th>

See Risk 7.

</th>  
<th>

1 / 3

</th>  
<th>

3 (3)

</th> </tr>  
<tr>  
<td>

11

</td>  
<td>

Data subjects do not understand how to exercise their rights under GDPR
Chapter 3.

</td>  
<td>

During the informed consent process, subjects receive (in writing) information
about their rights, how to exercise them, and who to contact. They are given
the addresses for the relevant pages on the project website, which explains in
full what their rights are and how they can exercise them.

</td>  
<td>

1 / 2

</td>  
<td>

2 (4)

</td> </tr>  
<tr>  
<td>

12

</td>  
<td>

Controllers do not adequately respond to data subjects who exercise their
rights under

GDPR Chapter 3.

</td>  
<td>

Controllers have provided the names of contact points for data protection in
their organisations. Each is an established university or research institute,
with experience and capacity of running research projects of this kind. The
FOCUS consortium also includes data protection experts who can provide advice
to consortium partners on demand.

</td>  
<td>

1 / 3

</td>  
<td>

3 (3)

</td> </tr>  
<tr>  
<td>

13

</td>  
<td>

Data subjects not able to withdraw their data from the aggregated dataset.

</td>  
<td>

The pseudonymisation process has been designed to ensure that the data is as
secure as possible while maintaining a possibility for subjects to withdraw
their data. As long as the subject has their individual code, they can have
their data removed from the aggregated dataset. The organisation responsible
for analysis of the dataset (CSS) will have the code numbers, but no link
between then code numbers and individuals. Hence if the subject contacts the
organisation who collected their data, they can verify their identity and ask
to have their data withdrawn. That organisation can then contact CSS to ask
them to remove the entries for that particular code number without having to
reveal the subject’s identity.

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

14

</td>  
<td>

Data subjects can be reidentified from the aggregated dataset.

</td>  
<td>

Data subjects _can_ be reidentified from the aggregated dataset, but _only_ by
selected members of the research team at the organisation that collected their
data. _In general_ , data subjects cannot be reidentified from the dataset.
Hence the likelihood that an individual _could_ be reidentified is, by design,
high; but the likelihood that they could be reidentified without their unique
code number is very low.

</td>  
<td>

1 / 2

</td>  
<td>

2 (6)

</td> </tr>  
<tr>  
<td>

15

</td>  
<td>

Data processors do not comply with their responsibilities.

</td>  
<td>

The data processors are employed under contract. In the case of Sweden/MAU,
they are a national body. In all cases they are professionals who have been
duly informed about the project and what they must do. Data controllers are
responsible for engaging only reliable data processors. The data controllers
are experienced in this kind of research and so the risks are very low.

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

16

</td>  
<td>

Adequate records of data processing not maintained.

</td>  
<td>

The data controllers are experienced in this kind of research and so the risks
of administrative problems such as this are very low.

</td>  
<td>

1 / 3

</td>  
<td>

3 (3)

</td> </tr>  
<tr>  
<td>

17

</td>  
<td>

Personal data transferred to third countries.

</td>  
<td>

The data that is transferred to Jordan will be aggregated and, effectively,
anonymised. Technically, the data is pseudonymised because there exists a code
that links the survey to an individual. But since the recipient in Jordan is
not in possession of and not going to receive those codes, from the
perspective of anyone but the controller who collected the data, it is
anonymous. Therefore personal data is not transferred between partners in the
fieldwork at all.

</td>  
<td>

1 / 3

</td>  
<td>

3 (3)

</td> </tr>  
<tr>  
<td>

18

</td>  
<td>

Personal or sensitive data that is not strictly

relevant to

FOCUS’s research goals or questions

may be volunteered during focus groups.

</td>  
<td>

Focus group moderators are experienced and will ensure that discussion stays
on topic. In case non-relevant sensitive data is volunteered, the moderator
will steer the discussion back on-topic. Such data

will be erased at the point of transcription.

</td>  
<td>

1 / 2

</td>  
<td>

2 (2)

</td> </tr>  
<tr>  
<td>

19

</td>  
<td>

Leaked data about an individual could negatively affect their asylum
application or status

</td>  
<td>

Individuals whose asylum application or status would be vulnerable to such an
event are, by design, not eligible to participate in the survey. Therefore the
likelihood of this happening is very low, and the severity is very low too.

</td>  
<td>

1 / 1

</td>  
<td>

1 (3)

</td> </tr> </table>

After the mitigations are applied, no risk has a likelihood of greater than 1.
This means that the risks are ‘remote’ and have thus been effectively
mitigated. They are nonetheless monitored, as per Step 7\.

###  Step 6: Documentation

This DPIA was conducted as part of the process of preparing for the fieldwork
to be conducted in FOCUS WP3 and WP4. The DPIA itself is included in the FOCUS
project Data Management Plan. As such, it is presented alongside:

  * **The Data Management Plan (DMP)** : this explains how data (personal _and_ nonpersonal) is generated and used during the project, and how the consortium meets its obligations to make as much of its generated data as possible available for public use by other researchers. In covering general data management in the FOCUS project, the DMP is clearly relevant to the DPIA and should be read alongside it. 

  

  * **The Ethics Management Plan (EMP)** : this explains how the consortium 

  

addresses the research ethics issues posed by the project. It includes
descriptions of the informed consent processes to be used for the fieldwork.
As such, the EMP is clearly relevant to the DPIA and should be read alongside
it.

###  Step 7: Monitoring

This DPIA was conducted by AND-CG. AND-CG is response for ethics management in
the FOCUS project. Part of our role, as the project continues, is to monitor
the data processing within the project. We will monitor data processing
against the DMP, the DPIA, and the GDPR more generally. The DMP will be
updated periodically throughout the lifetime of the project. We will review
the DPIA also to ensure compliance with its risk management approach.

[END OF DPIA]

####  7.2 Consortium ethics and data protection contact points

**Table 6** : Designated data and ethics management contact points in the
FOCUS project.  
  
<table>  
<tr>  
<th>

**Partner**

</th>  
<th>

**Data and Ethics Management Contact Point**

</th> </tr>  
<tr>  
<td>

Danish Red Cross (DRC)

</td>  
<td>

Martha Bird, _mabir@rodekors.dk_

Anouk Boschma, _anbos@rodekors.dk_

</td> </tr>  
<tr>  
<td>

AND Consulting Group (AND)

</td>  
<td>

Andrew Rebera, _rebera@and-cg.com_

</td> </tr>  
<tr>  
<td>

Faculty of Humanities and Social Science,

University of Zagreb (FFZG)

</td>  
<td>

Jana Kiralj, _jkiralj@ffzg.hr_

</td> </tr>  
<tr>  
<td>

Malmö University, Institute for Studies of

Migration, Diversity and Welfare (MAU)

</td>  
<td>

Pieter Bevelander, _pieter.bevelander@mau.se_

</td> </tr>  
<tr>  
<td>

University of Jordan, Center for Strategic

Studies (CSS)

</td>  
<td>

Walid Alkhatib, _w.alkhatib@css-jordan.org_

</td> </tr>  
<tr>  
<td>

Berlin Institute for Integration and

Migration Research at the Faculty of

Humanities and Social Sciences at

</td>  
<td>

Anna Brenner, _Anna.brenner@charite.de_

</td> </tr>  
<tr>  
<td>

Humboldt University of Berlin (HU) /

Charite

</td>  
<td>

</td> </tr>  
<tr>  
<td>

Arttic (ART)

</td>  
<td>

Andreas Schweinberger, _schweinberger@arttic.eu_

</td> </tr>  
<tr>  
<td>

Q4 Public Relations (Q4)

</td>  
<td>

Peter MacDonagh, _peter@q4pr.ie_

</td> </tr> </table>

###  8\. Ethics Management Plan

The first principle of the ALLEA _European Code of Conduct for Research
Integrity_ states that: “Good research practices are based on fundamental
principles of research integrity”.  33  In FOCUS, this is also our first
principle.

The key to recognising this principle’s force and, especially, its impact, is
to notice that it focusses not on the inherent value of research integrity as
something which is simply important in its own right (although this is
obviously the case), but rather on the status of research integrity as the
foundation of good, effective research. That is to say **, in order to
successfully pursue our goals in FOCUS, ethics and integrity are not
constraints or obstacles (as they are sometimes mistakenly, if understandably,
seen** 34  **), but values and objectives that make good research possible** .

This Ethics Management Plan describes how the FOCUS project embeds research
ethics and integrity into its activities as a key pillar of effective
research, and, of course, as a protection of the rights of research
participants and other stakeholders.

_Section 8.1_ (‘Ethics Management Structure’) sets out the management
structure that has been established in the project to implement and oversee
research ethics and integrity. It describes the role of consortium partners
and the Ethics Management Team. _Section 8.2_ describes the role of the
external Ethics Advisory Board, who provide independent advice and oversight.

Research in FOCUS is supported by participants from refugee and host community
groups. In all research involving humans, there are some basic principles that
should be respected. A number of sources are recognised as providing solid,
reliable standards for research ethics and integrity. Some of these, such as
_The European Code of Conduct for Research Integrity_ , deal specifically with
research ethics and integrity; others, such as the _Charter of Fundamental
Rights of the European Union_ , are more general statements of human or
fundamental rights. Some key resources are listed below.

**Key resources**

  * _The Nuremberg Code_ (1947) 

  

  * Council of Europe, _European Convention on Human Rights_ (1950/2010) 

  

  * World Medical Association, _Declaration of Helsinki_ (1964/2013) 

  

  * _The Belmont Report_ (1979) 

  

  * The Council of Europe, Convention for the Protection of Human Rights and Dignity of the Human Being with regard to the Application of Biology and Medicine: Convention on Human Rights and Biomedicine (The Oviedo Convention) (1997) 

  

  * Council for International Organizations of Medical Sciences (CIOMS), _International Ethical Guidelines for Health-related Research Involving Humans_ (2016) 

  

  * UNESCO, Universal Declaration on Bioethics and Human Rights (2005) 

  

  * European Union, _Charter of Fundamental Rights of the European Union_ (2012) 

  

  * ALLEA, _The European Code of Conduct for Research Integrity_ (2017) 

  

Respecting the principles encoded in these documents generally requires such
steps as: gathering genuinely informed consent from participants; carefully
balancing any foreseeable risks to participants against the likely benefits of
the research; ensuring that research findings are not misused; and ensuring
that confidentiality and the privacy rights of participants are protected.
However, **as widely recognised – including by the European Commission DG
Research and Innovation in their _Guidance Note for research with refugees,
asylum seekers, and migrants_ ** 35  **– research with refugees usually
entails further specific commitments, recognising the increased vulnerability
of some potential research participants** .

Moreover, the subject of _integration_ is a sensitive one, particularly
considering current societal and political tensions in Europe. As such,
_section 8.3_ (‘Key ethics issues in FOCUS’) discusses specific concerns
raised by research in this area and indicates how our general principles of
research ethics and integrity can be applied in concrete situations in FOCUS.
This section also includes discussion of the consortium’s compliance with the
General Data Protection Regulation (GDPR).  36

####  8.1 Ethics management structure

Ethics management in FOCUS is based around a four-tier system of progressively
moreindependent oversight and advice.

**Table 7** : 4-tiered ethics management structure  
  
<table>  
<tr>  
<th>

**Tier**

</th>  
<th>

**Responsible**

</th>  
<th>

**Description**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

\- All partners

</td>  
<td>

**Tier 1: Acknowledgement of responsibility**

At tier 1 each consortium member commits to ensuring that appropriate
standards of research ethics, research integrity, and privacy are respected
throughout the project and in all its activities.

The partners undertake to ensure that the rights of research participants and
the core values embedded in the EU Charter of Fundamental Rights are respected
and promoted at all stages of the project.

Each partner will appoint at least one person as their ethics point of
contact, who will be responsible for liaising with the Ethics Management Team
(see _section 7.1_ above).

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

\- AND

</td>  
<td>

**Tier 2: Ethics Manager and Ethics Management Team**

Tier 2 sees the basic implementation of internal ethics management in the
project. In FOCUS this is largely (but not only) through Task 1.3.

The Ethics Management Team will be run by AND.  37  The Ethics Management Team
is available to provide partners with information, advice and support for any
ethical or data protection issues that arise during the project.

The Ethics Manager will be Dr Andrew Rebera. Andrew has a DPhil in

Philosophy and is also an IAPP (International Association of Privacy
Professionals) accredited “Certified Information Privacy Manager”

(CIPM).  38  Andrew is highly experienced in collaborative research, projects
and specialises in ethics management (i.e. coordinating the development,
implementation, and oversight of management structures aimed at ensuring
excellence in research ethics, data protection, and privacy).

The Ethics Manager will be supported by Mr Dimitris Dimitriou. Dimitris holds
MSc degrees in Health Psychology and Environmental Psychology. He is
specialised in ethics risk management and communication, with

</td> </tr> </table>  
<table>  
<tr>  
<th>

</th>  
<th>

</th>  
<th>

extended experience on ethics-related research in the fields of ICT and health
risk communication.

The Ethics Management Team will carry out the following activities in the
project:

  * draft and periodically update the project’s DMP and EMP; 

  

  * coordinate the Ethics Advisory Board (EAB) (see tier 3 below); 

  

  * provide detailed research ethics input to the fieldwork and pilottesting methodologies; 

  

  * support partners in obtaining the Research Ethics Committee (REC) approvals for fieldwork; 

  

  * develop research ethics validation procedures for fieldwork and pilot testing. 

  

</th> </tr>  
<tr>  
<td>

3

</td>  
<td>

  * AND 

  

  * EAB 

  

</td>  
<td>

**Tier 3: Ethics Advisory Board (EAB)**

The EAB consists of three external (i.e. non-consortium) advisors. Their role
is to provide feedback, advice, and recommendations on relevant ethical,
fundamental rights, privacy and data protection, and societal issues.

The EAB was appointed in the first months of the project, from suggestions put
forward by the consortium. The EAB will meet face-toface twice during the
project and will otherwise hold virtual meetings at least every 6 months. The
Ethics Manager will coordinate and chair EAB meetings.

The EAB is entitled to: (a) review any project deliverables or relevant
internal working documents; (b) review research protocols; (c) request contact
with any researcher involved in project; (d) take action – including
contacting the coordinator, the EC Project Officer, or other Commission
officers – to ensure that relevant issues are appropriately handled.

(Further details in _section 8.2_ .)

</td> </tr>  
<tr>  
<td>

4

</td>  
<td>

  * All partners collecting significant (by volume or sensitivity) personal 

  

data

  * AND 

  

  * EAB 

  

</td>  
<td>

**Tier 4: External Ethics Approvals (Research Ethics**

**Committees)**

Tier 4 concerns measures to collect and submit all required ethics and data
protection approvals from the competent bodies, such as local Research Ethics
Committees (RECs) and national Data Protection Authorities (DPAs).

We anticipate the need for the following REC approvals:

  * REC approvals for field research in Germany; 

  

  * REC approvals for field research in Sweden; 

  

  * REC approvals for field research in Croatia; 

  

  * REC approvals for field research in Jordan; 

  

  * We also anticipate a potential requirement for REC approvals for pilot testing activities in WP5 (taking place in Denmark, Sweden, Austria, Germany and the United Kingdom). However, since the methodology for the pilot-test will not be prepared until the 2  nd  year of the project at least, we cannot say with certainty whether approvals will actually be required. 

  

In all decisions as to what approvals are required, we will be guided by the
Ethics Management Team, the many experienced and senior

</td> </tr>  
<tr>  
<td>

</td>  
<td>

</td>  
<td>

researchers in the FOCUS team, the EAB, and any support from the Project
Officer or project reviewers.

In all applications for approvals, the Ethics Management Team will, as
necessary and as requested, support the lead partners in preparing research
protocols and other supporting documentation; but it remains the
responsibility of the partner leading the research activity to obtain all
required approvals. Authorisations, opinions, and notifications received from
competent bodies will be retained by the lead partners, with copies –
translated if necessary – submitted to the coordinator and the Ethics Manager
upon request. These will be included (e.g. as annexes) in project management
reports to the EC.

The consortium recognises that sensitive data may be collected during
fieldwork. The old Data Protection Directive (95/46/EC) required data
controllers to notify the relevant supervisory body (the national Data

Protection Authority (DPA)) for certain acts of data processing. The GDPR
takes a different approach, with notification being only required in certain
very specific circumstances. Following the data protection impact assessment
reported in _section 7.1_ , we do not need to notify national DPAs of our
processing activities. (This is discussed at a greater level of detail in
_section 8.3_ .)

The Ethics Management Team will use the REC approvals in developing the ethics
validation procedures for fieldwork and pilot testing. This will ensure that
all requirements stipulated by the RECs are implemented.

</td> </tr> </table>

####  8.2 Ethics Advisory Board (EAB)

The FOCUS consortium aims to ensure that the highest standards of research
ethics and privacy are respected throughout the project, particularly bearing
in mind the risks and challenges associated with research involving refugees
and forced migrants. The Ethics Advisory Board (EAB) is an important component
of the project’s overall ethics management structure. This section is the
basis of the **EAB** **Terms of Reference** that define the EAB’s role, and
set out EAB members’ duties and responsibilities.

#####  8.2.1 Mission

The role of the Ethics Advisory Board (EAB) is to provide the FOCUS consortium
with feedback, advice, and recommendations on relevant ethical, fundamental
rights, privacy, data protection, and societal issues.

#####  8.2.2 Independence

The EAB is independent from the consortium in the sense of having no
significant stake in the success or failure of the project. The EAB’s role is
simply to provide advice on what is required in order to ensure best-practice
with respect to ethics, fundamental rights, privacy, data protection, and
societal issues, particularly taking into account the rights and interests of
any research participants (including personal data subjects). Members will,
when signing up for the EAB, confirm that they are independent of the
consortium and have no relevant conflicts of interest. The EAB will not be
remunerated for serving on the EAB but will be reimbursed (by the Danish Red
Cross) for travel expenses incurred in the course of their duties.

#####  8.2.3 Membership

The EAB consists of three external (i.e. non-consortium) advisors. EAB Members
may be experts in ethics and/or fundamental rights, privacy and data
protection experts, academics working in areas related to the project, or
representatives of relevant NGOs or CSOs. A formal professional position or
qualification in ethics or privacy is not necessary: the idea is to have an
interdisciplinary group, with different backgrounds, but a common interest in
the ethical issues surrounding research with refugees and migrants. EAB
members serve in a personal capacity (not on behalf of any institution).
Membership of the EAB is voluntary.

#####  8.2.4 Appointment

EAB members will be selected by the Ethics Management Team. Membership is
voluntary and does not constitute employment or affiliation to any consortium
member. If a member resigns their position, the Ethics Management Team will
appoint a replacement as soon as possible.

#####  8.2.5 Termination of membership

An EAB member wishing to resign their position should inform the Ethics
Management Team in writing at the earliest possible moment.

#####  8.2.6 Conflict of interest

EAB members are required to declare any actual or perceived conflict of
interests to the Ethics Management Team.

#####  8.2.7 Meetings

The EAB will meet face-to-face twice during the project and will otherwise
hold virtual meetings at least every 6 months. Agendas will be provided no
less than 10 (ten) working days before commencement of the meeting. Dr Andrew
Rebera will coordinate and chair EAB meetings. A member of the Ethics
Management Team will take minutes (no other recording of the meeting will take
place). Meetings will be attended only by EAB members and the Ethics
Management Team.

#####  8.2.8 Decision-making

Any decisions or recommendations that the EAB provides (e.g. approving
feedback to the coordinator) will be approved by majority voting. Note that
while the Ethics Management Team may attend EAB meetings and contribute freely
to discussion, they are not members of the board and have no voting rights:
voting rights are only enjoyed by the EAB members (the role of the Ethics
Management Team is only to serve as a bridge between the EAB and the
consortium). When consensus cannot be reached among the EAB members, decisions
will be taken by majority voting, but minority opinions will be reported in
meeting minutes. If a decision is required between meetings, agreement and
voting will be conducted via email.

#####  8.2.9 Feedback to the consortium

Minutes of EAB meetings will be prepared by the Ethics Management Team and
circulated to the attendees for approval. Opinions will be minuted without
attribution to particular EAB members (Chatham House Rule). EAB members will
be asked to provide feedback and approve the minutes within 10 (ten) working
days. The minutes will include an Executive Summary (summarising discussions
and presenting any EAB decisions or recommendations) which will be shared with
the consortium and the European Commission Project Officer.

#####  8.2.10 Travel

The EAB will be reimbursed for reasonable travel expenses incurred attending
the face-toface meetings. All travel arrangements and expenses will be handled
by the Danish Red Cross. AND-CG will put EAB members in contact with the
relevant Danish Red Cross team members in order to arrange travel and
reimbursement.

#####  8.2.11 Responsibilities

EAB members shall:

  1. Offer advice and recommendations on any ethical, fundamental rights, privacy, or societal issues reported to them by the Ethics Management Team or project coordinator. 

  

  2. Support the consortium by providing feedback concerning research ethics standards and privacy/data-management in the development of research methodologies in the project (particularly for the field work [WP3, WP4] and pilot testing [WP5] activities). 

  

  3. Review and provide advice concerning research protocols prepared by partners seeking approvals from research ethics committees (RECs) or data protection authorities (DPAs). 

  

  4. Review and, as necessary, suggest improvements to the project Ethics Management Plan and relevant sections of the project Data Management Plan. 

  

  5. Review and, as necessary, suggest improvements to any project deliverable selected by the Ethics Management Team. 

  

  6. Actively participate in EAB meetings (2 face-to-face, teleconference at least every 6 months). 

  

  7. EAB members shall not disclose to any third party any confidential information acquired in the course of their participation without the prior approval of AND-CG and/or the project coordinator. In the unlikely event that we need to share sensitive confidential information, members will be asked to sign a non-disclosure agreement. 

  

  

#####  8.2.12 Powers

The EAB is entitled to:

  1. Review any project deliverables, research protocols, or internal working documents. 

  

  2. Request contact with any researcher involved in project. 

  

  3. Contact the project coordinator or European Commission project officer. (EAB decisions, recommendations, and opinions will be communicated to the coordinator, consortium and project officer via the Ethics Management Team. However, should the EAB so wish, they may get into contact with anyone involved in the project directly, via the coordinator). 

  

  

#####  8.2.13 EAB members

The members of the EAB are:

  * **Brigitte Lueger-Schuster** , who is an Associate Professor for Clinical Psychology at the University of Vienna. She has a background in psychology, human rights, psychosocial work with refugees, and has been involved with ethics and data protection boards. 

  

  * **Julia Muraszkiewicz** , Juris Doctor, who is a Research Manager at Trilateral 

  

Research where she leads the team’s work on human trafficking research and

innovation, working on security, human rights, crisis, gender and privacy-
social impacts of policy and innovative solutions.

  * **Mozhdeh Ghasemiyani** , who is a crisis psychologist for Doctors without Borders and the Danish Institute against Torture. Mozhdeh has specialist expertise in trauma, refugees and crises. She has worked in government, local government and NGO’s in Denmark, UK, US to improve the treatment of refugees, especially children. 

  

#####  8.2.14 EAB meeting dates

**Table 8** : EAB prospective meeting dates  
  
<table>  
<tr>  
<th>

**ID**

</th>  
<th>

**Dates**

</th>  
<th>

**Description**

</th> </tr>  
<tr>  
<td>

1

</td>  
<td>

22 Mar 2019

</td>  
<td>

1  st  teleconference [agenda and minutes available]

</td> </tr>  
<tr>  
<td>

2

</td>  
<td>

8-9 May 2019

</td>  
<td>

1  st  face-to-face meeting, Zagreb (in conjunction with WP3 workshop) [agenda
and minutes available]

</td> </tr>  
<tr>  
<td>

3

</td>  
<td>

5-9 Sep 2019

</td>  
<td>

2  nd  teleconference

</td> </tr>  
<tr>  
<td>

4

</td>  
<td>

2-6 Dec 2019

</td>  
<td>

3  rd  teleconference

</td> </tr>  
<tr>  
<td>

5

</td>  
<td>

6-10 Apr 2020

</td>  
<td>

4  th  teleconference

</td> </tr>  
<tr>  
<td>

6

</td>  
<td>

1-5 Jun 2020

</td>  
<td>

2  nd  face-to-face meeting, location to be confirmed

</td> </tr>  
<tr>  
<td>

7

</td>  
<td>

3-7 Aug 2020

</td>  
<td>

5  th  teleconference

</td> </tr>  
<tr>  
<td>

8

</td>  
<td>

30 Nov – 4 Dec 2020

</td>  
<td>

6  th  teleconference

</td> </tr>  
<tr>  
<td>

9

</td>  
<td>

5-9 Apr 2021

</td>  
<td>

7  th  teleconference

</td> </tr>  
<tr>  
<td>

10

</td>  
<td>

9-13 Aug 2021

</td>  
<td>

8  th  teleconference

</td> </tr>  
<tr>  
<td>

11

</td>  
<td>

6-10 Dec 2021

</td>  
<td>

9  th  teleconference

</td> </tr> </table>

####  8.3 Key ethics issues in FOCUS

This section presents research ethics challenges identified in the project.
These will be updated throughout the project lifetime as necessary. The issues
are presented in alphabetical order, not order of importance.

(Please note that the **FOCUS Research Ethics Manual** , developed for the
purposes of the fieldwork research planned to be carried out in the scope of
WP4, provides practical advice and recommendations in relation to most of the
points presented below, but is specific to the fieldwork. The Research Ethics
Manual is included as an _Annex_ to this document.

#####  8.3.1 Confidentiality

_Challenge_

In conducting research in refugee communities, particularly when using methods
such as snowballing to recruit participants, it is essential to ensure that
all information gathered is kept fully confidential. Besides storing data
securely and data pseudonymisation techniques implemented by all research
teams, researchers should be careful not to reveal information about (or from)
one participant to another. In some circumstances, if a researcher tells a
participant that the previous participant said such-and-such it may be
possible for the participant to figure out who the previous participant was.
It is also important to ensure that all researchers understand and agree to
their responsibilities regarding confidentiality, particularly if they have
been recruited as cultural insiders, translators or interpreters, or from the
target population, in which case their own cultural confidentiality
expectations may be different (Olijiofor 2016: 6-7). Confidentially must of
course also be respected in the publication of findings.

_Response_

In FOCUS we use experienced and/or trained researchers, who have been fully
briefed on the nature of the project, and on the nature of their
responsibilities regarding research ethics and integrity (see FOCUS Research
Ethics Manual). The briefing will be conducted by the senior researchers of
each partner conducting fieldwork or pilot-testing.

#####  8.3.2 Cross-cultural factors

_Challenge_

Europe is itself a multi-cultural society, but working with refugees from
beyond Europe makes it inevitable that cross-cultural factors will be relevant
in the project, especially in research design and research ethics. Failure to
take cultural differences into account in research design and data collection
risks undermining relationships with participants (Olijiofor et al. 2016: p.
4).

One fundamental challenge – which is quite commonly remarked in the literature
– is that in cross-cultural contexts there may be different understandings and
expectations of what is ethical (e.g. what constitutes coercion). On a more
specific level, cultural differences between researchers and research
participants may lead to misunderstandings, misperceptions, and divergent
expectations concerning informed consent, privacy and so on.

_Response_

Although all FOCUS field research teams already have extensive experience in
research with refugees, cultural insiders will, as far as is possible, be
included on the research teams. Birman (2005: 170) describes this as “the most
important strategy” in working with refugees, since it “ensure[s] that
understanding of the community and culture informs the ways in which [research
ethics] aspects of the study are designed and implemented.”

A cultural insider is someone who knows the language and culture of the target
group in virtue of being a member of that group (Birman 2005: 171-72). The
advantage of a cultural insider is that they have “inside” knowledge of the
target group. But, of course, it is not possible for anyone to have _full_
knowledge of the target group – particularly bearing in mind the issues
discussed elsewhere concerning diversity within target populations – and, as a
speaker of the research language and a member of the research team, the
cultural insider is likely to be considered an outsider by the target group to
a certain extent and in a certain sense. So, the idea of a “cultural insider”
is an abstraction and we do better to think in terms of a continuum, rather
than of a simple insider/outsider binary (Birman 2005: 172).

Cultural insiders are important team members for recruiting participants,
building good relationships, and carrying out field research. Cultural
insiders can also have an important role in research design. This is an
important way of ensuring that their insights are built into the structure of
the study and of the fieldwork. As far as possible, cultural insiders should
be academically trained researchers, as senior as possible. Given the
important and influential role of cultural insiders, it is important that the
cultural insiders in the project are themselves diverse, as far as possible
(e.g. a balance of genders, ages, ethnicities, religions, etc.).

Recruitment of cultural insiders is not always easy. In FOCUS we will strive
to meet the standards outlined above as well as possible. Inevitably, in some
cases it will not be possible to fully meet all standards perfectly. At a
minimum, we will consult cultural insiders regarding the issues mentioned
above (i.e. even if they are not full members of the teams). In all cases, we
will rely on the extensive experience of the FOCUS field research teams in
research with refugees.

#####  8.3.3 Dissemination and Communication of Findings

_Challenge_

The subjects of migration, immigration policy, and the integration and
assimilation of forced migrants and refugees are frequently divisive, often
bound up with other emotive topics such as terrorism and security, and, as
such, are of great political and societal significance. It follows that a
research project such as FOCUS, which address itself directly to these
subjects, must pay great attention to the way in which its findings are
disseminated, communicated, and used. Research in this area cannot be morally
neutral (Birman 2005: 155), for it inevitably feeds into ongoing morally
significant debates, not least concerning policymaking. Indeed, it is an
explicit intention of the project that its findings should inform policymaking
in the area. In FOCUS it will be essential to consider how our findings might
be interpreted or used, once they are disseminated.

_Response_

All dissemination materials will be subject to an internal review process by
the consortium before they are cleared for release. Each partner will bring
particular expertise, e.g. research partners can verify scientific quality and
the Ethics Management Team can verify compliance with research ethics and
integrity standards. The consortium is experienced enough to be able to
determine whether a publication is suitable for release. In cases of doubt,
the Advisory Board and the EAB will provide independent advice.

8.3.4 Flexibility and “Learning-as-we-go”

_Challenge_

It is recognised in the literature that, especially in cross-cultural
contexts, no one set of ethical guidelines can ever be a perfect guide to
best-practice (see e.g. Birman 2005: 175; Jacobsen & Landau 2003: sec. V;
Olijiofor 2016: 7). It is important to think deeply and continually about how
to ensure the highest standards of research ethics.

_Response_

We recognise that not every single issue of research ethics and privacy can be
foreseen before the work begins. We have therefore designed the ethics
management structure to ensure that research ethics is constantly monitored
and that there are clear communication channels between the Ethics Manager,
the Ethics Advisory Board, the coordinator, and the partners. This is in
addition to a project-wide commitment to being flexible about how ethical
considerations may influence other tasks, and to “learning-as-we-go”, i.e.
periodically reflecting on our performance, on challenges that have been
encountered, and on how we can be better at being better. While best-practice
can be set out in broad terms, flexibility in how the research is conducted is
both necessary and inevitable.

The FOCUS consortium has put a lot of thought into how research ethics, with
particular sensitivity to the challenges of working with refugees, can be
built into the project (particularly with respect to field work: see WP3 and
WP4). For example, the WP3 methodological workshop, held in Zagreb in May
2019, set out the principal requirements and procedural steps in relation to
the fieldwork, which enabled the Ethics Management Team and the Ethics
Advisory Board to provide targeted feedback and produce key outputs for
partners involved in the research. Since then, the ‘Interviewer Manual’ and
‘Training Manual’ have been developed by research partners following the WP3
workshop, which provide more information on procedural aspects of the research
with refugees and host community members. These further inform the research
ethics feedback that the Ethics Management team can provide. The process is an
ongoing one and that is as it should be.

#####  8.3.5 Incentives to Participate

_Challenge_

In conducting research with refugees, there is likely to be a power
differential between researchers and research participants. Refugees may have
an uncertain legal status, they may have reduced rights or opportunities, they
may be in a difficult economic position, and they may be uncertain of the
rights and obligations of other actors (organisations, public bodies, etc.).
This may, on the one hand, disincentivise them to participate in research, due
to suspicion or mistrust of those conducting or funding the research. On the
other hand, it may lead to misunderstandings of the voluntary nature of
participation. They may feel obliged to participate, or that participation is
somehow linked to other institutional processes they are engaged in (Krause
2017) (such as citizenship applications), or that research interviews are
somehow connected with other interviews that concerned their legal status
(Ellis et al. 2007: 466), or that it is “the done thing” to participate, or
that it makes good sense to participate because it will (they suppose) support
their integration in various concrete ways (e.g. that it will make them more
attractive to employers, etc.).

Moreover, when participants are recruited through gatekeepers or by
snowballing, it can be difficult to fully ascertain people’s reasons for
participating. Researchers may be only dimly – or not at all – aware of the
power relationships between participants and the people or organisations that
introduce them to the project. It should not be taken for granted that those
who introduce new participants to the project understand the research process
in the same way as the project researchers (Olijiofor 2016: 6).

If financial or other incentives or reimbursements are provided these should
be provided equally to all participants in a transparent way. The procedure
for receiving the payment or reimbursement should be made clear to
participants in advance and should be carefully thought through. For example,
proposed payments direct to a bank account may be problematic if individuals
or groups have reduced or no access to banking services; or if participants
are required to provide a social security number this may exclude those who
either do not have one or who prefer not to give it).

_Response_

It will be made clear to potential participants, more than once, that their
involvement with the project is in no way whatsoever connected with their
legal status, their economic prospects, etc. That is to say, the overwhelming
incentive to participate is simply to support the research and its aims. This
will be made clear to all potential participants, whose contribution to
research will also be acknowledged in partners’ publications and dissemination
activities. In such context, stakeholders and project partners from all
representative countries benefit from this equally.

Financial incentives to participate will be clearly stated in the research
design and will be no more than 20€ or equivalent (e.g. shopping coupons). In
the case of focus group sessions, information about monetary reimbursements
for participation in a session is included in both the Letter of Invitation
and the Information Sheet. It is our intention that there be as little
variation in methodology and other factors (e.g. incentives) across research
sites. In practice, this is unlikely to be possible. However, we will strive
to ensure, as much as possible, that the relative value of incentives provided
is constant across sites (e.g. relative to local cost of living).

#####  8.3.6 Informed Consent

_Challenge_

Informed consent procedures are an essential component of responsible
research. Properly designed and implemented, an informed consent procedure
ensures that potential research participants can take the decision to
participate (or not to) on the basis of a sound understanding of: the aims and
scope of the project; the team(s) conducting it and the organisation(s)
funding it; the aims, scope, and specific details of the particular research
activity to which they are invited to contribute; and the risks, benefits, and
any other relevant and likely consequences, of participating.

There are a number of benefits to be gained by implementing a good informed
consent procedure. These include benefits to participants, such as protecting
their rights, and enabling them to identify breaches of or threats to research
ethics standards connected with their participation; and benefits to the
research, such as developing strong and trusting relationships with
participants, potentially leading to greater engagement and higher quality
contributions. So there are many incentives to get informed consent right.

A well-known concern is that informed consent forms can be long, overly
technical, use specialist terms or jargon, and can have a legalistic “small
print” style. This can have the effect of either discouraging participation or
of undermining a participant’s understanding of what they are signing up to
(which is unfair, undermines their autonomy, and sacrifices all the benefits
of a good informed consent procedure). A further shortcoming of poorly
written, legalistic or jargon-filled informed consent forms is that they may
prove difficult to translate effectively – which is to say, in a manner that
is both faithful to the original text but also easily comprehensible to
readers (Birman 2005: 166).

Refugees may be or feel in a precarious legal or immigration position. As
such, they may be willing to participate in the research on an anonymous
basis, but unwilling to sign informed consent forms. It is important that an
informed consent procedure does not obstruct participation. Accordingly, a
flexible approach is required. In cases such as those mentioned above (but
also others, e.g. when a participant has limited literacy) consent can be
provided orally (Olijiofor 2016, 5; Ellis et al. 2007: 467-69). The same
information as is provided on the informed consent form and information sheet
should be communicated orally to the participant (and the same points about
comprehensibility apply). The participant should provide an explicit
indication of consent. If the participant agrees, this process should be
recorded (video or audio). If the participant does not agree, or if this is
not possible, then the process should ideally be witnessed by a second member
of the research team. If there is no second member in the research team, then
it is the researcher’s responsibility to ensure that informed consent
principles apply in practice, including participants’ right to withdraw from
the research and have their data removed at any point. Researchers should keep
records, for all participants, whether fully anonymous or not, of how informed
consent was obtained and what records (forms, videos, etc.) are stored.

Informed consent is a process, not an event. This is most obviously reflected
in the fact that consent is always revocable, i.e. a participant can withdraw
his/herself and his/her data from the study at any time, for any reason. (In
cases of anonymous participation, withdrawal of data may not be possible.) It
also implies that researchers should be alert to signs of distress or
discomfort, and should be sensitive to the needs of participants. It may take
time and dialogue for a participant to agree to take part, and they may need
reassurance and open discussion of concerns after having agreed in order that
they feel comfortable to continue. The interests of the participant always
come before the interests of the work and so it is imperative that researchers
set aside sufficient time to collect informed consent in fair and effective
ways.

_Response_

In FOCUS we will develop a flexible approach to informed consent which is
consistent with both the requirement to clearly record consent and the
requirement to minimise the processing of personal data. In the qualitative
data collection process in WP4, our intention is to collect as little personal
data from participants as possible. The research partners will apply a
pseudonymisation technique to ensure that survey respondents are to almost all
intents and purposes anonymous, but nonetheless retain the possibility to have
their data withdrawn at any time in the research.

Informed consent forms will bear a unique code, corresponding to the same code
on the participant’s questionnaire. This enables the data to be processed
pseudonymously from the point of view of the party collecting the data and
anonymously from the perspective of everyone else. The informed consent forms
will be kept separately from the questionnaires (to minimise the risk of the
two becoming somehow associated).

Participants in focus groups will provide written informed consent (we need
their contact details in order to organise the workshops, hence obtaining
written informed consent requires gathering no additional data).

The Ethics Management Team has provided feedback and recommendations in the
development of the Information Sheets (and Invitation Letter, in the case of
focus groups). In addition, the Ethics Management Team produced two types of
Informed Consent Forms:

a) interview surveys, and b) focus groups. Consent will be granular, meaning
that consent to specific aspects of the research (particularly the data
processing aspects) will be distinct from other acts of consent.

#####  8.3.7 Language and Translation

_Challenge_

Translation – of informed consent forms, information sheets, data collection
tools (e.g. questionnaires) and results – is a difficult but very important
matter. It is obviously important that translations are as accurate as
possible.

Translation of certain terms is likely to be problematic, either because they
are relatively technical (and so the problem is to render them in terms that
preserve the meaning – assuming that a single common meaning is agreed upon
within the consortium – while also being understandable to non-experts), or
because some phrases or terms have cultural connotations that are absent in
either the source or target language, or because – if interpreters are used –
they inadvertently introduce biases into the data (Olijiofor et al. 2016: 4).

_Response_

Data collection in fieldwork will, as necessary, be conducted in the language
of the participants. In EU countries where research will be conducted, there
will be two versions of the questionnaires: one provided in the local
language, and the other one in Arabic. Backtranslation will be used, whereby
the source document is translated from English into the target language and
then the translated document is translated back into the English by a
different translator, and the two English versions are compared to ensure that
the sense has been adequately preserved through the process (Jacobsen & Landau
2003; Bloch 2004: 14546). To address issues of unexpected or unintended
cultural connotations, translated materials will be reviewed with cultural
insiders or members of the target group (e.g. community leaders).

#####  8.3.8 Privacy and Data Protection

_Challenge_

The rights of participants with respect to data protection are set out in
legislation, most notably the EU General Data Protection Regulation (the
GDPR). The GDPR mandates 7 basic principles relating to the processing of
personal data:

  * _**lawfulness, fairness and transparency** _ : personal data shall be processed lawfully, fairly and in a transparent manner. 

  

  * _**purpose limitation** _ : personal data shall be collected for specified, explicit, and legitimate purposes, and not further processed in a manner incompatible with those purposes. 

  

  * _**data minimisation** _ : personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. 

  

  * _**accuracy** _ : personal data shall be accurate and kept up to date; reasonable steps must be taken to ensure that inaccurate data are erased or rectified without delay. 

  

  * _**storage limitation** _ : personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary. 

  

  * _**integrity and confidentiality** _ : personal data shall be processed securely, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage, using appropriate technical or organisational measures. 

  

  * _**accountability** _ : the controller shall be responsible for, and be able to demonstrate compliance with, the above principles. 

  

_Response_

The above basic principles form the basis of the approach adopted in FOCUS.
Data minimisation was reviewed in WP3 during research design. This is
reflected in the DPIA reported in _section 7.1_ above. In general, each
partner is responsible for justifying to the consortium each form of personal
data they propose to collect. The Statement of Compliance with the Principle
of Data Minimisation – endorsed by all consortium partners – describes the
means by which we ensure that any data collected and processed in FOCUS is
relevant and limited to the purposes of the project:

######  Statement of Compliance with the Principle of Data Minimisation

_“The processing of personal data is essential to the fieldwork conducted in
FOCUS. The consortium undertakes to ensure that the minimum amount of data is
processed. To ensure this, a standardised methodology is developed in WP3 to
ensure that all partners collect the same type of personal data by means of a
single instrument, to be developed and used across the different countries
where research takes place. This information will be collected in the Project
Data Management Plan. The Ethics Manager will review these categories and,
with the support of the WP3 work package leader, will ensure that there is
adequate justification for gathering that data. Any categories of data that
cannot be shown to be genuinely necessary for the scientific integrity of the
fieldwork will be rejected: researchers will be instructed to not collect that
data (and research plans adjusted if/as necessary). In case of any doubt or
debate, the Ethical Advisory Board will be called upon to provide a final
decision.”_

As a consortium, we have stipulated that the standards mandated by the GDPR
will be applied in relation to fieldwork in Jordan by non-EU data controllers
even if it is not legally required (CSS reports that it has its own data
protection software and independent offline servers.) FFZG, as lead of
research design confirms that any research activities carried out in Jordan
regarding methodological aspects, data anonymisation/pseudonymisation
techniques, data collection and conduct with the participants, data management
and data protections will be the same as in other countries. No research will
be conducted in Jordan that would not be conducted in the EU country within
the exactly same research framework. We have reviewed data protection
practices in Jordan to determine whether they impose restriction stronger than
those in the GDPR (they do not).

It is important to note that there will be no transfer of personal data
between consortium partners and therefore – to be quite specific on this point
– no transfer of personal data to or from Jordan. Any data to be transferred
to Jordan for the purposes of between-country analyses will be in aggregated
form only, and effectively anonymous at that stage (reidentification would
only be possible for the party that collected the data).

All research partners have agreed to use a standard pseudonymisation technique
by which each survey participant will be ascribed a numerical code indicating
only the serial number of the completed questionnaire (i.e. from 001 to 999)
at each study site. Data such as the name or address of the participant will
not be recorded on the questionnaire. The questionnaire will not collect any
data that could, in itself, be linked to identifiable individuals. The name of
participants will only appear in signed copies of informed consent forms,
which will be kept separate at all times from the questionnaires.

Participants in the focus groups will not be addressed by their (real) names
if they choose so. The records with their names which are needed only to
establish contact will be kept separately from the audio recordings and the
transcripts in a locked cabinet. Similarly, to the survey interviews, each
participant will be ascribed a unique code which will be used in the
transcripts of the focus groups (pseudonymisation). Data in the transcripts
that could lead to identification of an individual will be deleted prior to
data processing. Audio recordings will be destroyed immediately after
producing the transcripts and a protocol testifying this will be kept by the
senior researcher at each fieldwork site.

A strict data minimization policy will be adopted in the project in order that
no personal data which is not strictly necessary will be gathered from
participants. The personal data collected via the informed consent form
includes participant’s name and surname. The Letter of Invitation designed for
the recruitment of participants for the focus groups, also requires from
participants to indicate their profession and provide an email address or
phone number to get in contact for organisation matters regarding the focus
group session. As stated above, any such data are kept separately from
participants’ responses as part of the fieldwork. Whenever participants are
requested to submit personal data, they will be informed of what data is
collected, how it is stored and processed, and by whom.

A small amount of sensitive personal data is collected during the survey
concerning racial or ethnic origin, religious and political beliefs, and
health. This data has been agreed as necessary by experts in the consortium.
It is scrupulously minimised. Participants will be explicitly informed of this
data collection before consenting. This is addressed in the DPIA in _section
7.1_ above.

Participants’ data will not be mined or used for any purposes other than those
explicitly stated and clearly necessary for the relevant activity within
FOCUS. We will comply with the general principles listed above, as well as the
specific requirements of the GDPR, as set out in its later articles and
recitals.

#####  8.3.9 Research Design

_Challenge_

It is a basic principle of research ethics that the risks to participants must
be outweighed by the benefits (to the participants and/or to others) of the
likely outcomes of the research (this formulation is rather too simplistic,
but for present purposes the point holds). The most obvious implication of
this is that research which involves very serious risks to participants should
be likely to have very significant benefits. In designing their research,
therefore, researchers must minimise risks to participants. However, it also
follows from the basic principle that researchers should, in designing their
research, aim to maximise its positive and valuable outcomes. In practice,
maximising positive outcomes and minimising risks to participants is a
balancing act.

That a balance must be struck should not be taken to imply that research
ethics and effective research design are in tension, or that there is a trade-
off to be made: good practice in research ethics promotes effective research
design (Olijiofor et al. 2006; Ellis et al. 2007: 462). For example, a
carefully designed informed consent procedure will build trust between
researchers and participants, making it more likely that participants provide
candid and full responses to researchers’ questions. Or again, careful
attention to diversity and hierarchies of power and social capital within a
target population is good practice in research ethics, but it also makes it
more likely that the data gathered will be accurately reflect the diversity of
perspectives in that population. Looking at it from the other side, carefully
designed research methods promote ethics. A number of factors are noted by
Jacobsen & Landau (2003: sec. III), including:

  * _**sampling** _ : that the sample should be genuinely representative; 

  

  * _**construct validity** _ : that what is measured should be appropriately linked to what it is assumed to show; 

  

  * _**objectivity** _ : that researchers’ subjective biases do not intrude into data collection or interpretation; 

  

  * _**reactivity** _ : that a researcher’s presence does not influence participants’ responses; - _**translation** _ : that inaccuracies and biases do not contaminate the data; and: 

  

  * _**lack of use of control groups** _ : control groups are often omitted in social science research involving refugees. 

  

Similar requirements, which are not necessarily tailored to refugees, are
identified by a number of other authors – Emanuel et al. (2000), for instance.
Ellis et al. (2007: 462-71) developed these requirements, shifting the focus
onto refugees. They identify the following important factors:

  * _**social or scientific value** _ : that the research contributes to increasing knowledge and that the findings be disseminated; 

  

  * _**scientific validity** _ : that the research should be methodologically sound, especially given the challenges of cross-cultural contexts ; 

  

  * _**fair subject selection** _ : that subject selection is driven by the requirements of the research question, not by the ease or difficulty of accessing participants; 

  

  * _**favourable risk/benefit ratio** _ : that potential benefits to participants 

  

(individually and collectively) outweigh potential risks;

  * _**independent review** _ : that research proposals are reviewed by, e.g., funding bodies, RECs, etc., and by members of the refugee community; 

  

  * _**informed consent** _ : that participation is voluntary and on the basis of an adequate understanding of the research project and what is involved in taking part; 

  

  * _**respect for potential and enrolled participants** _ : that researchers address the power differential between them and the participants, e.g. by involving cultural insiders in research design. 

  

Research design and research ethics should, therefore, be developed in tandem.

It is also important that research participants are shown respect as persons,
and not objectified or treated as “mere research subjects”. This kind of
respect can be built into the research design by, for example, ensuring that
participants are given time and opportunity to speak their minds freely (and
possibly even on matters that go beyond the research questions), rather than
simply being “mined” for their data (Krause 2017: 20).

_Response_

The Ethics Management Team have contributed significantly in the process by
reviewing materials developed in the scope of WP3, and have involved the
Ethics Advisory Board in the process by having all members attending the WP3
Methodological Workshop help in Zagreb in May 2019, providing structured
feedback and opinion on several aspects of the research. It should however be
noted that the academic partners responsible for research design and
implementation are senior and highly respected professionals, with extensive
experience of this kind of research design with refugees and other vulnerable
groups.

More information on basic inclusion/exclusion criteria and procedures to be
implemented for the identification and recruitment of research participants
are provided in _section 8.3.14_ (“Selection and recruitment of participants”)
below.

#####  8.3.10 Research Ethics Training

_Challenge_

Any recruited researchers – including interviewers, translators, interpreters,
and anyone else involved in, e.g., identification of participants – should be
given some project-specific training in research ethics issues (cf. Olijiofor
2016: 8).

_Response_

Each partner will ensure that all researchers and associated people conducting
the research are experienced and/or well-trained in both the scientific and
ethical aspects of their tasks. The Ethics Management Team has developed the
**FOCUS Research Ethics Manual** (see _Annex_ below) which aims to provide
practical guidance to fieldwork interviewers on ethicsrelated aspects of the
research.

#####  8.3.11 Research integrity

_Challenge_

Research integrity is a central responsibility of all researchers. Some
authors have raised concerns in this field about “advocacy research”, i.e.
“where a researcher already knows what she wants to see and say and comes away
having ‘proved’ it” (Jacobsen & Landau 2003: 187). This is typically well-
meaning, but it undermines the quality of academic and societal debate, and
possibly skews policymaking.

_Response_

In addition to respecting the fundamental principles of research integrity
(see The European Code of Conduct for Research Integrity, ALLEA 2017), we
acknowledge the concerns mentioned above. To mitigate this risk, in FOCUS we
will develop research methodologies in a transparent way (e.g. the research
design is coordinated separately from the research implementation), will
encourage critical discussion of the methodology and of the findings and how
to interpret them, and will ensure that results are effectively communicated
alongside clear and open explanations of how the data was gathered and
interpreted.

#####  8.3.12 Rights of Participants

_Challenge_

The rights of participants with respect to data protection are discussed in
_section 8.3.8_ above. Besides privacy, all other standard rights of research
participants will be respected. These include:

  * that participation shall be voluntary; 

  

  * that participants shall be clearly and adequately informed of the purpose of the research, what it involves, and how the findings will be used; 

  

  * that there is no undercover data collection or use of deceptive practices; 

  

  * that participants may withdraw themselves and their data (if possible) from the project at any time and for any reason; 

  

  * that participants shall be respected as persons, not merely “research subjects”; 

  

_Response_

The Ethics Management team have worked in WP3 to ensure that respect for all
such rights is built into the research design. We will also be developing an
“ethics validation procedure”, which will enable us to monitor whether the
rights have been respected in practice. More specifically:

  * _**Voluntariness** _ . Participation in any research activity in FOCUS will be entirely voluntary. Researchers will be alert to signs of coercion, especially when participants are introduced to the project through snowballing or through their employer. 

  

  * _**Informed consent** _ . Participants who cannot give genuinely informed consent (e.g. 

  

minors) will not be included in the research. All related materials (e.g.
informed consent forms) will be provided in a language with which the
participant is comfortable and can fully understand (where this cannot be
confirmed, the participant will be excluded from the study).

  * _**Follow-ups** _ . Participants will be provided the name and contact details of a member of the research team whom they can contact at any stage after the research (e.g. in case of complaint or a request to withdraw data). 

  

  * _**Withdrawal** _ . Participants retain the right to withdraw themselves and their data (if possible) at any time for any reason. They will be informed how to indicate this intention. 

  

  * _**Risks/benefits of participation** _ . Participants will be briefed as to the possible risks or benefits of participation. Participants will not be placed in any situation in which there is a likelihood of physical or psychological harm. There may be a risk of recalling mental or emotionally stressful events but not larger than occurs in their everyday discussion with peers. Benefits of participating are that one supports the research and its goals. If any form of reimbursement is provided, this will be 

  

provided to all participants and with as much equivalence across research
sites as possible (see _section 8.3.5_ ).

  * _**Cultural, religious, other issues** _ . Possible cultural, religious, or other issues (e.g. kinds of food provided at workshops) will be identified in advance and measures will be taken in order to avoid any offence or embarrassment. 

  

  * _**Respect for participants** _ . Participants will be shown respect as persons, not merely “research subjects” by inviting them to provide feedback (if they wish) on their experience in the research activity to which they contributed. This will be achieved by informal conversations with researchers and/or feedback forms provided to them (some may prefer to talk, some to provide anonymous feedback). The forms will include a freeform open section in which the participant can say whatever they like about their experience. The forms and feedback will be anonymous (though the participant can add their name and contact details if they wish) and entirely voluntary (not obligatory at all). 

  

#####  8.3.13 Security of Researchers

_Challenge_

Researchers conducting fieldwork should be informed of any risks involved.

_Response_

It is not expected that researchers conducted fieldwork will be at any non-
normal risk. This will, however, be verified, prior to commencement of the
fieldwork. The likelihood of researchers encountering difficult or upsetting
stories will also be assessed and a support framework will be assured by the
individual partners responsible.

#####  8.3.14 Selection and Recruitment of Participants

_Challenge_

It should not be assumed that identifying forced migrant and refugee
populations will be simple (Jacobsen & Landau 2003). Identification of
potential research participants in FOCUS will be a challenge. Strategies to be
employed include snowballing techniques and access to registries. Such methods
are not perfect. In terms of effectiveness, people of uncertain or precarious
immigration status may be reluctant to take part in research studies, fearing
that it may bring them to the attention of the authorities, regardless of who
introduced them to the project; and in terms of quality, such methods are
somewhat susceptible to selection bias and concomitant danger in drawing
generalisations (Olijiofor 2016: 14). In addition to the methodological risks,
snowballing carries the ethical risk of potentially harmful information being
revealed within a participant’s social network. As Jacobsen & Landau (2003:
sec. III) point out, “simply informing a respondent how you obtained a name or
contact information demonstrates a particular kind of link” .

Moreover, determining the target populations within the broader grouping
“forced migrants and refugees” increases in difficulty as the diversity within
the broader group increases. This also raises an issue concerning sample size
and makeup. It is, generally, desirable to collect large samples. To be of the
most value, these samples must be relatively homogenous; but not only can it
be difficult to identify suitable populations, it can also be difficult to
collect samples that represent (at a suitable size) the different subgroups
with in the target population. This can lead to minority groups being either
ignored or subsumed into majority groups (Birman 2005: 161; Ellis et al. 2007:
464), or to results which are questionably representative and which do not
allow comparative studies across groups (Jacobsen & Landau 2003: sec. III). It
should be further noted that if (as is not uncommon) there is a dearth of
reliable statistics on, for example, the ethnic or religious makeup of the
population, it will be difficult to conclusively determine whether steps taken
to ensure a balanced and representative sampling have been successful. These
problems have an impact on the reliability of the research findings – which is
particularly problematic when the research is intended to inform policymaking
in a critical area (Birman 2005: 163).

_Response_

It should be noted that such problems will afflict any study of this kind to
some extent. Our approach in FOCUS, which draws on the recommendations of
Birman (2005: 163-4) is to openly acknowledge the problem, to address it as
far as possible in WP3 and WP4, and to carefully record – and include in the
reporting of our findings – the limitations of the research methods. To
address the limitations of snowballing, we will attempt to ensure use of
multiple starting points (Bloch 2004: 149).

We do not underestimate the seriousness of this challenge. As stated
elsewhere, FOCUS is fortunate in benefitting from the involvement, at senior
project positions in research design and implementation, of highly respected
professionals, with extensive experience of this kind of research design with
refugees and other vulnerable groups. We will rely on these colleague’s
experience and expertise, alongside input from the Advisory Board and EAB, to
provide high quality assurances of effective, methodologically and ethically
sound selection and recruitment of participants.

Below, we provide an account of the procedures and criteria that will be used
for identification and recruitment of research participants for the conduct of
surveys and focus groups in the scope of WP4. The following information is
taken from the Training Manual developed by WP3 leaders FFZG.

The four study sites will include Germany, Sweden, Croatia and Jordan focusing
on communities with high concentration and number of refugees. The survey
target groups include host community members and refugees from Syria living in
the respective communities.

The target group of refugees from Syria is described as forced migrants from
Syria who have been recognized as refugees by UNHCR from 2011 onward in
Jordan, or have received the international protection status (asylum) from
2015 onward for European countries, and have been living in respective host
communities from the point of receiving this status to date. The criteria of
different years of being recognized as a refugee (in Jordan) or receiving
asylum (in Europe) was chosen since the peak of influx of refugees from Syria
to Jordan was in 2013, but the refugees from Syria started arriving in greater
numbers in 2011/2012. The European Union experienced massive increases in
influx of refugees in 2015. The inclusion criteria for ascent to the study
are:

  * Age – respondents between 18 and 65 years. 

  

  * Refugee/asylum status – respondents who have received the decision regarding their status; if rejected the refugee/asylum status do not qualify for the study. 

  

  * Year of receiving refugee status – respondents who received their refugee/asylum status after 2015 (2011 in Jordan) qualify for the study. In Jordan the applicable criteria for acknowledging the refugee status will be used. 

  

  * Not living in a camp/shared accommodation for refugees – respondents who live in a camp or shared accommodation for refugees do not qualify for the study. 

  

Host community members are defined as persons who have citizenship or
permanent residency in the respective European country and have been living in
the same host community for at least 7 years (at least since 2013). The
criterion of length of stay in the same community has been chosen as a sum of
two years prior to the beginning of the migration wave from Syria to Europe
and the number of years passed since, making a total of 7 years. For Jordan,
the host community members are defined as Jordanians, as in Jordan foreigners
cannot receive citizenship or permanent residence. It is important that the
survey participants in the host communities are long-residing individuals in a
respective community to have been able to develop profound experience of
living in and attachment to the community. The inclusion criteria for ascent
to the study are:

  * Age – participants between 18 and 65 years. 

  

  * Number of years living in the respective country – participants living in the host community more than 7 years. 

  

  * Citizenship or residence – participants who have country citizenship or permanent residence. 

  

**Sampling host community participants**

Survey of host community members will use two probabilistic sampling
techniques to select the participants. Due to specific differences among the
four study sites regarding access to registers of host community members, the
Random Walk Technique (RWT) will be used in Germany, Jordan and Croatia. In
Sweden, citizen registries will be used for randomised selection of
participants and the validated interviewing procedures will be followed as in
other similar population based studies in Sweden.

In the selected target areas (regions, cities) the size of the sample will be
proportional to the population of that target area (region, city), and
participants will be selected by probability sampling which will ensure that
the sample structure reflects the areas’ population characteristics based on
available statistics, such as the total male and female population in the 18
to 65 age group.

**Sampling refugee participants**

The sampling design for the refugee survey will aim at achieving heterogeneity
to reflect the refugee population parameters, but true probabilistic sampling
is not expected at all study sites. RWT of sampling refugee respondents will
be used if possible in Jordan, while random sampling of refugees based on
registries will be used in Sweden. In Germany and Croatia refugee respondents
will be approached through NGOs that maintain contact with them and if needed
with advertisements and invitations to participate in the study that will be
placed and published at locations frequented by refugees from Syria.

During the initial contact with potential refugee participants the Information
Letter about the study and invitation to participate will be distributed
through the NGO channels. If they are willing to participate, they will send
message through the NGO intermediary and will then be contacted.

In order to minimise the potential self-selection and other referral biases,
in each area (region, city) at least five different entry points into the
target population (i.e. NGOs, locations for placing the advertisements and
invitations to participate in the study) will be used.

Data collection will be conducted in a comparable way across countries using
the standard and validated procedures, such as computer assisted personal
interviewing (CAPI) or faceto-face paper and pencil interview in the language
preferred by the participants, using the same questionnaire, and in all cases
carried out by trained staff.

Participants in the qualitative part of the study will be recruited into 4 to
5 focus groups of key informants among the host and refugee community members
in the same cities where the quantitative survey will be done. Both host and
refugee participants will be identified among the general population using
different information channels and reaching out to, for example, schools, work
places, welfare services, job services and other locations where the potential
participants will be approached to ascent to the study. The focus group
participants will be modestly reimbursed for their effort. The key informants
will be defined as individuals (both women and men, between 18 and 65 years of
age), who have been living in the respective community at least seven years,
are aware of the presence of refugees living in the community, and are able to
articulate their experiences and views. The principle of maximal heterogeneity
regarding the age, education level and gender will guide the recruitment of
focus groups composition. The focus groups will be held in the mother tongue
of the participants.

**Quality assurance during data collection**

While gathering data, the interviewers will maintain a separate “survey log”
in the paper format for each completed and attempted interview. In this log
they will note the address, time, date and outcome of each completed or
attempted interview, whether original or replacement household.

At the end of the interview, the participants will be asked if they agree to
be contacted by the survey supervisor for the purpose of monitoring the work
of the interviewers. If the participant agrees, his/her phone number will be
written in the specific follow-up table together with the participant’s
personal code. This will enable the survey supervisor to verify about 10 % of
the completed interviews per each interviewer. The telephone numbers will be
randomly selected among the participants who have agreed to be called back. If
selected for the follow-up call, the supervisor will ask the participant if
he/she was interviewed during the previous three days at home (or in case of
refugee participants possibly at other locations) by means of a tablet about
the integration of host community members and refugees. The supervisor will
not be able to identify the individual participant.

In case of irregularities, the personal code will serve to delete this
participant’s data. In such a case, all other interviews done by the same
interviewer will be also deleted. Such interviewer will be immediately
dismissed and other interviewers will collect data from the replacement
households and participants.

The survey logs will be kept separate from the participants’ responses which
will be entered into the tablet computer during the interview and in no way
will they be linked to the data of an individual participant.

To avoid interviewer bias, none of the interviewers will interview more than
15% of the sample, i.e. a maximum of 90 participants from at least nine
sampling points.

#####  8.3.15 Vulnerability

_Challenge_

Forced migrants and refugees may often face discrimination in virtue of their
status as immigrants. They may also face other forms of discrimination that
exist in their host society (in terms, e.g., of race, gender, religion,
disability, poverty, etc.). Moreover, immigrants from any given region
themselves have diverse backgrounds in terms of ethnicity, socioeconomic
status, religion, and many other factors. This means that an individual may be
vulnerable to discrimination within that group. Research design – particularly
the selection of participants and research assistants – should, as far as
possible, take account of this diversity and potential for discrimination.
This does not necessarily mean that the selected participants should
thoroughly reflect the make-up of the groups studied – although in some cases
it may – but it implies that the problem of gathering appropriate reliable
data from an appropriate range of the target population should be
acknowledged, carefully considered, and effectively addressed.

Refugees are more likely than most others to have experienced traumatic
events. It should be established whether and to what extent the research
activities in which they are asked to participate are likely to cause them
suffering or, at least, to revisit difficult experiences (Krause 2017: 4). It
should also be mentioned that participants in trauma-related research can
benefit from the experience (Ellis et al. 2007: 465). So the risk of
participants revisiting difficult experiences is something to be assessed and
reflected upon, rather than an automatic barrier to research.

_Response_

The Research Ethics Manual (see _Annex_ ) contains information on ethical
factors to consider when working with refugees from Syria. It is, of course,
important to be realistic about what can be offered (Krause 2017: 24-5):
offering to follow-up with participants and then not doing it may be harmful
(as well as disrespectful). Hence the same opportunities will be offered to
all participants, regardless of their location, which includes at minimum
providing the contact information of the person available to offer counselling
services at each study site.

At the same time, the consortium will be careful to ensure that participants
are not subject to a sort of condescending paternalistic attitude (Ellis et
al. 2007: 471). As mentioned elsewhere (see _section 8.3.5_ on incentives to
participate), it is important that researchers are sensitive to the power
differentials between them and the research participants, balancing the duty
to protect the interests of participants with respect for their dignity and
autonomy and, as far as possible, promoting a reciprocal approach (Krause
2017: 15) whereby participants also gain from their participation in some
manner (e.g. pride in having supported research that aims to foster better
policymaking).

#####  8.3.16 Incidental Findings

_Challenge_

Incidental findings may arise in different research contexts, and specifically
in human participant research, which involves the collection of data beyond
the aims and scope of the study. It is important to establish appropriate
procedures to handle and minimise the risk of occurrence of any such findings
in the context of fieldwork planned in the scope of this project.

_Response_

We will take all possible steps to minimise the risk of incidental findings,
and in this direction, we have produced a statement of FOCUS’ Incidental
Findings Policy.

**Incidental Findings Policy**

Before fieldwork commences, each partner conducting fieldwork will establish
whether data that could be inadvertently collected is likely to raise any
ethical or legal issues (e.g. if it concerns criminality, legally grey or
questionable issues, or urgent health issues). We will seek advice from the
Ethical Advisory Board and experts from the consortium to determine the best
policy for dealing with such incidental findings.

The blanket policy for incidental findings that do not raise any of the issues
mentioned above is that they will be immediately deleted. Decisions to delete
incidental data must be approved by a senior researcher in the project.

Whenever incidental findings arise, the researcher must report this to the
task or WP leader and to the Ethics Manager. This is because it is necessary
to establish why the incidental findings arose. If it is due to research
design, then the methodology will be adjusted to prevent future occurrences.
The task or WP leader will maintain records of anonymised cases of incidental
findings and how they were addressed.

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