#  Introduction

The BlockStart project (hence, “BlockStart” or the “Project”) and all its
consortium partners have implemented the necessary measures in order to comply
with the applicable National and European laws on personal data protection.
For the avoidance of doubt, BlockStart, as a Coordination and Support Action,
does not involve research activities and therefore, will not require to
generate, collect and/or process research data, namely, involving and having
as research scope personal data.

This document will present the policies, principles and implemented measures
to ensure the said compliance hereunder with the applicable personal data
protection requirements, contextualized with an overview of relevant data
flows and datasets occurring throughout the Project, and constitutes the core
of the applicable detailed data protection policy for the Project.

#  Purpose of the personal data processing under the Project

The processing regarding personal data that may occur under the Project will
be strictly related to its use for the purposes of (and without prejudice of
the fact that in many cases the relevant entities will be legal persons and,
as such, the corresponding data used for such purposes will not constitute
personal data):

  * sending communications by email to the professional contacts of the potential interested entities related to the relevant calls and events; 

  

  * involving the participating entities in the developed activities under this Project; 

  

  * executing the due fund transfers for the involved entities under the Project terms and conditions; 

  

  * complying with any reporting obligations in relation to the European Commission under the Project. 

  

No personal sensitive data (defined by Article 9 of the GDPR as “data
revealing racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, (…) 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”)
will be collected by the BlockStart project.

#  Personal data categories

As said, under BlockStart, as a Coordination and Support Action, research
activities will not be carried out and therefore, and the activities to be
carried under the Project will not generate, collect or involve the processing
of research data, namely, involving and having as research scope personal
data.

Nevertheless, in order to manage, execute and implement the Project measures
proposed in the corresponding Work Packages, it will create a dataset
containing personal data about the professional contacts of data subjects
working for and/or representing the entities that participate in the
BlockStart’s activities (e.g.: DLT developers, SMEs, DLT experts,
intermediaries, policymakers), as point of contacts of such entities, for the
purposes mentioned above, as well as defined and established in the Work
Packages.

Therefore, the only personal data processed by the BlockStart consortium
encompasses the following personal data categories:

  * full name; 

  

  * professional email; 

  

  * professional telephone contact; 

  

  * country of establishment; 

  

  * short CV and/or LinkedIn profile; 

  

  * bank accounts of beneficiaries (DLT developers, SMEs, DLT experts), in order to enable the due fund transfers to the aforementioned sub-grantees; 

  

  * attendance sheets (with names and signatures of people present at events); 

  

  * photo and video recording of events (e.g.: ideation kick-offs, workshops, demo days, webinars). Such recordings (e.g.: general perspective of an auditorium, video of a beneficiary pitch, testimonials by the participants), to the extent applicable in accordance with the applicable personal data protection laws, will only capture people that had expressed consent for the use of their image (limited to the promotion of BlockStart’s open call and results). 

  

#  Who will have access to personal data

Only the BlockStart consortium parties will have access to the said personal
data and, within the BlockStart consortium parties organizations, strictly
only its representatives, directors, employees, advisors and/or subcontractors
that have a need to know basis, and ensuring that persons authorised to
process the personal data have committed themselves to confidentiality or are
under an appropriate statutory obligation of confidentiality. Technical and
operational measures will be implemented to ensure that users/relevant data
subjects will be able to access, rectify, cancel and oppose processing and
storage of their personal data.

#  How long personal data will be stored

The gathered personal data under the Project will be stored by the
Controller(s) until the end of the Project (February 2022). Data (including,
if strictly needed, personal data processed by the BlockStart consortium
parties in accordance with the current terms) needed to answer to potential
audits by the European Commission services (e.g.: data that enables the
assessment of BlockStart activities’ impact), may be kept for up to 5 years
after the end of the Project (prospectively until May 2027) and, to the extent
applicable, the potential processing of the relevant personal data for such
purpose would be supported on the necessity of the consortium parties to
comply with an applicable legal obligation to which such entities are subject
to hereunder. However, any personal data may always be deleted earlier, if a
data subject explicitly requests their records to be deleted and the
applicable requirements to the exercise and execution of the right to erasure
are fulfilled. In order to follow the principle of data minimization, personal
data will be deleted/destructed the earliest possible, in accordance with the
applicable criteria and requirements resulting from the applicable personal
data protection laws, namely, the General Data Protection Regulation (“GDPR”).

#  How personal data will be collected and processed

BlockStart consortium will put into place several measures to ensure full
compliance with the applicable personal data protection requirements, namely
through:

###  Personal Data Processing Principles Compliance

Personal data processing will be carried out in compliance with the applicable
personal data processing principles, namely:

  1. such processing activities must be lawful, fair and transparent; 

  

  2. it should involve only data that is necessary and proportionate to achieve the specific task or purpose for which they were collected (Article 5(1) GDPR); 

  

  3. personal data will be requested only when strictly needed, and only for the purposes stated when personal data is requested. When requesting personal data, disclaimers will be shown, with a clear statement of the purpose of collecting and keeping such information; 

  

  4. personal data shall be kept accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; 

  

  5. personal data storage will be limited for no longer than is necessary for the purposes for which the personal data are processed; 

  

  6. personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. 

  

  

###  Compliance with applicable national and EU legislation

All the personal data that will be processed under this Project will be
processed in compliance with the applicable international, EU and national law
(in particular, the GDPR, applicable national data protection laws and other
relevant applicable laws on this matter). All BlockStart consortium partners
comply with the applicable national and EU laws in force regarding personal
data protection. All BlockStart activities will be carried out in compliance
with the GDPR.

###  Informed consent procedures

Individuals whose personal data is collected by BlockStart consortium partners
within the frame of BlockStart Project (namely, through registration on the
consortium partner F6S platform, through submission of contact/newsletter sign
up/other forms within BlockStart website, and other online tools managed by
the BlockStart consortium as, for example, a webinar platform) will be
informed, upon collection of such personal data, of the processing terms of
their personal data.

Such information knowledge is confirmed by the individual by ticking the box
expressly confirming that the individual has taken knowledge of the applicable
BlockStart Personal Data Protection Policy (which terms are presented at
_www.blockstart.eu/data-protection/_ )  , where applicable terms to the
processing of personal data under the Project is detailed and explained to the
corresponding data subject (“BlockStart Personal Data Protection Policy”).

In particular, personal data collected through the consortium partner F6S
platform will be collected in accordance with the said applicable laws (on
that matter, and to the extent applicable, F6S datarelated policies are
accessible through the following links on the mentioned platform:
_www.f6s.com/privacy-policy_ ;  _www.f6s.com/terms_ ;  _www.f6s.com/data-
security_ ; _www.f6s.com/cookie-policy_ ; _www.f6s.com/cookie-table_ )  .

The legal agreements signed within the frame of the BlockStart Project (e.g.:
agreements with external evaluators, and sub-grantees - DLT developers and
SMEs) include articles concerning the compliance with ethical standards and
guidelines, as well as binding such entities to the applicable personal data
protection laws requirements.

The contract to be signed with sub-grantees will refer to the obligation to
conduct their activities following such principles, in a responsible manner
and complying with applicable legislation and H2020 rules and guidelines.

In the case of evaluators, the contract signed includes the signing of a Code
of Conduct which, among others, includes the principles of fairness,
independence, impartiality, and confidentiality.

The data collected through interviews and focus groups with SMEs, as well as
wider surveys sent out to a panel of SMEs across European countries, with data
collection including information related to regulatory and supervisory bodies,
industry associations, innovation hubs, major companies, major SMEs and
innovators, research organisations, legal service providers, consulting
service providers, major funding providers (VC, angel investors, PE, etc.) and
under the open call evaluations, will not include personal data collection.

###  Right to information, access, rectification, erasure, restriction of
processing, data portability, object and not to be subject to a decision based
solely on automated processing, including profiling

Data subjects whose personal data is being processed under the Project can
contact the Project Coordinator (via the contact information in BlockStart
Personal Data Protection Policy) to exercise their rights in accordance with
the applicable personal data protection laws.

###  Anonymization/pseudonymization of personal data

Anonymization of the processed personal data under BlockStart will be
performed through the use of aggregated and statistical data whenever
possible.

The objective of these techniques is to ensure that the data subject is not
directly or indirectly identifiable or re-identifiable. Recital 26 of the GDPR
establishes that “to determine whether a natural person is identifiable,
account should be taken of all the means reasonably likely to be used such as
singling out, either by the controller or by another person to identify the
natural person directly or indirectly”. Assessing what “reasonably likely”
means becomes a key point in the risk assessment of re-identification, in
which all objective factors and contextual elements will be taken into
account. The cost, amount of time required, and available state-of-the-art
technology are aspects to be considered when assessing what means are
“reasonably likely” to be used in attempting to re-identify data.

It should be recalled that, as the GDPR states, “the principles of data
protection should therefore not apply to anonymous information, namely
information which does not relate to an identified or identifiable natural
person or to personal data rendered anonymous in such a manner that the data
subject is not or no longer identifiable. This Regulation does not therefore
concern the processing of such anonymous information, including for
statistical or research purposes”.

To avoid the risk of re-identification, whenever possible, and to minimize it
when true anonymization is not possible, the BlockStart Consortium will set up
a range of measures and safeguards in relation to the datasets provided by
beneficiaries and other entities. The measures consist in limiting access to
the datasets (only when needed) and legal agreements in place containing
clauses to this effect (compliance with data protection regulations).

Full datasets will be accessible only under certain conditions, when necessary
for the implementation of the Project. This will reduce the risk of
unauthorised identification of data subjects in the datasets, and will allow a
higher control of any misuses of data.

DLT developers will only have access to the SMEs datasets and the right to
carry out data processing over them during the Pilot. Unless an additional
agreement is reached between SMEs and the DLT developers, the developers have
the obligation to delete the data once the Pilot ends.

Selected sub-grantees (both DLT developers and SMEs) will sign a sub-grant
Agreement with Bright Pixel as BlockStart Coordinator. This agreement will
establish the rights and obligations of the parties. Among others, it will
include personal data protection clauses, including:

  * the acknowledgement that the sub-grantees will be the data controllers of any new dataset or piece of personal information that the sub-grantees may produce in the course of the Pilot process; 

  

  * the obligation not to try to re-identify anonymised data; 

  

  * the obligation to delete, at the finalization of the Pilot process, the data to which the subgrantees has been granted access during the Pilot process, except an agreement is entered into with the SME; 

  

  * Declaration of Honour: to be signed at the time of the Sub-grant Agreement. This declaration will, among other topics, include the commitment to comply with data protection regulations and the commitment not to use the data for purposes other than those within the BlockStart framework; 

  

  * confidentiality clause: the datasets made available will be classified as “confidential”. While the confidentiality clause is irrelevant in personal data protection, its compliance would minimize the harm caused in case of breach of the personal data protection. 

  

#  Description of data flows

BlockStart main data flows result from the activities deriving from four Work
Packages (WP): WP2 (Engage), WP3 (Prototype), WP 4 (Pilot) and WP5 (Impact).

Here is a summarized description of the most relevant data flows:

##  Data flow 1: Engage

From the beginning of BlockStart Project, until the end of the third open call
(around July 2021), the consortium will develop activities under the Engage
phase (Work Package 2) that will demand the processing of data (including, in
some cases, personal data).

Firstly, in order to define the open call themes and sectors, a Sector
analysis activity will take place. Each sector will be mapped through desk
research of public available information covering regulatory and supervisory
bodies, industry associations, innovation hubs, big companies, SMEs,
developers, entrepreneurs and innovators, research organisations, legal
service providers, consulting service providers and major funding providers
(VC, angel investors, PE, etc.). Discussions with DLT experts, corporates and
SMEs will help validate the information gathered. The professional contacts
needed to get in touch with the aforementioned entities will be obtained from
public sources (company websites and Linkedin accounts) and organization
contacts within the consortium partners’ network. This activity will result in
brief one-pagers describing DLT feasibility and potential for DLT in SMEs per
key sector, with only aggregated information being presented.

Subsequently, a DLT Assessment Tool will be built, and made publicly
available, so that SMEs may check their potential for DLT implementation.

With the main sectors defined, BlockStart programme orientations and DLT
Assessment Tool publicly available, the open call will be ready to receive
applications from DLT developers, SMEs and external experts. At least two
webinars per call are planned to clarify the conditions of BlockStart open
call and programme. When registering for these webinars (via a dedicated page
for those particular events, on F6S platform), people wishing to attend will
need to provide their name and professional email.

Applications should be submitted through F6S platform (
_www.f6s.com/blockstart_ )  , following F6S data-related policies (
_www.f6s.com/privacy-policy_ ; _www.f6s.com/terms_ ;
_www.f6s.com/datasecurity_ ; _www.f6s.com/cookie-policy_ ;
_www.f6s.com/cookie-table_ )  . Some personal data, mentioned in section “3.
Personal data categories” of the present document, will be requested, in order
to assess the applicants, and contact the selected ones. Applicants will be
asked to sign a declaration of honor assuring the information provided is
true.

Consortium members and advisory board will evaluate the applications of
external experts.

Consortium members, external experts and advisory board will evaluate the
applications of SMEs and DLT developers.

All evaluators, acting pro-bono or being paid under a subcontractor's
contract, have to sign a declaration certifying: (i) that they will perform a
confidential, fair and equitable evaluation; (ii) their independence from
affiliation; (iii) confidentiality and absence of conflict of interest
(disqualifying or potential); (iv) that they will not discuss the proposals
with others during the process; (v) strictly, that they will not get in
contact with applicants; (vi) compliance with EC rules.

##  Data flow 2: Prototype

After the Engage phase, the Prototype stage will follow. It will start with an
Ideation Kick-off, an event organized to connect the 20 selected DLT
developers with 10 SMEs and mentors from the consortium, advisory board and
external experts. At the end of the event, 10 DLT developers will be selected.

Product and technical development of DLT prototype will take place in the
following 4 months, with the developments done by the 10 selected DLT being
continuously validated by users (selected SMEs, advisory board and other
potential customers), through meetings and mentorship facilitated by the
consortium partners.

DLT developers will be asked to sign a sub-grantee contract, provide legal
documentation that verify their existence as an entity, proof of bank account
and a summary of their activity (describing solution, process and development
log), in order to receive a grant for the Prototype development.

Professional contacts of all aforementioned participants will be vital to
allow the Ideation kick-offs and remaining Prototype activities.

##  Data flow 3: Pilot

In the third and last stage of BlockStart’s call process, the evaluators will
determine which 5 DLT solutions developed during the Prototype should be
selected to continue to Pilot stage. A group of 20 SMEs will also be selected.
DLT developers will be evaluated on the quality of the solution,
implementation readiness and interest shown by SMEs, with SMEs being chosen
mostly based on the results obtained through the DLT Assessment Tool. Just
before the development of the Pilots, DLT developers will be encouraged to
agree with individual SMEs on a “collaboration strategy” (e.g: exclusive use,
discounted use or free use of DLT solutions for an initial period).

Throughout the development and implementation of the Pilots in the SMEs,
consortium partners will work as facilitators of the relationship between all
parts involved. This follow-up will be operationalized namely through meetings
and bi-weekly updates with developers.

In the end, successful Pilots will be presented in a Demo Day event, targeting
investors, SMEs and other potential clients, industry associations and other
types of intermediaries.

A public DLT solutions portfolio (basic information about the projects) and
public Beneficiaries dataset (including list of entities who signed a sub-
grantee contract, project description and funding received) are due at the end
of BlockStart programme.

##  Data flow 4: Impact

Taking place in parallel to Engage, Prototype and Pilot phases of each call,
“Work Package 5 - Impact” will include a set of initiatives devised to
disseminate the lessons learned throughout BlockStart.

One of the cornerstones of the Impact Work Package will be creation of Sector
specific DLT maturity assessments. These will mainly consist in public reports
about the potential for DLT implementation in specific sectors, with
aggregated and statistical data based on desk research, interviews to SMEs and
intermediaries, use of DLT Assessment tool by SMEs, Prototype and Pilot
developments and feedback from participant DLT developers and SMEs. These
reports will be disseminated through BlockStart website and directly to
potentially interested stakeholders, like government organizations, legal
bodies, SMEs and industry associations.

Besides the document format itself, reports will also sustain the creation of
training resources like webinars and physical workshops to interested
intermediaries (governmental agencies, research institutions,
acceleration/incubation programmes and other agents detected throughout
BlockStart). These trainings will be disseminated through BlockStart online
platforms, consortium members websites and social media channels, presence at
events devoted to DLT/Blockchain and directly to intermediaries whose contacts
are publicly available. The ultimate goal will be to empower intermediaries to
help in the promotion of DLT adoption by SMEs.

Best practices and recommendations deriving from BlockStart will also be
shared with policymakers, aiming to clarify the Blockchain phenomenon, thus
facilitating the development of a compelling regulatory framework and
government support activities. This will be achieved not only through reports,
but also the organization of workshops and a conference, for which will be
invited entities like national governments, relevant ministries (Economic,
Finance, Transportation, etc.), Central Banks, Industry associations (Banking,
Financial Services, Insurance, Fintech), representatives of European Central
Bank, European Banking Authority, European Security and Market Authority,
European Insurance and Occupational Pension authority, and other European and
national authorities.

BlockStart consortium will make these invitations through the public contacts
available in the aforementioned institutions websites, and the training
initiatives will, by default, share aggregated information. If a particular
use case (referring to an organization, never an individual person) deserves
that an exception is applied to this principle, it will always need to be
accompanied by an explicit consent by the corresponding organization.

#  Datasets

The datasets resulting from the BlockStart’s data flows described in the
previous section (“7. Description of data flows”) are presented in the tables
below, each including the following fields:

● **Dataset reference:** a unique reference to each of the datasets

###  ● Relevant work package(s) ● Description of the dataset

  * **Data utility:** to whom could the data be useful and the reason why it is worth generating, keeping and/or sharing 

  

  * **Type:** collected, generated 

  

  * **Nature:** text, numbers, image, video, etc. 

  

  * **Scale:** the expected size of the dataset in MB/GB 

  

  * **Origin:** where does the data in the dataset come from, from which sources it has been collected 

  

  * **Archiving and storage:** where the data will be stored 

  

  * **Data sharing policy:** stakeholders with whom the data will be shared 

  

  * **Preservation time** ● **Additional preservation cost**

  

##  Open call applicants

_Table 1 Dataset Open call applicants:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-1

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

**Relevant work package(s):**

</td>  
<td>

WP2 Engage, WP3 Prototype, WP4 Pilot

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

**Description of the dataset:**

</td>  
<td>

Name, professional contacts and other data (described in section “3. Personal
data categories” of this document) needed to contact and assess applicants -
DLT developers, SMEs and external experts

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

**Data utility:**

</td>  
<td>

Personal data needed to contact DLT developers, SMEs and external experts, in
order to better assess them (during open call selection stage), and to connect
with the selected ones (in the scope of the Prototype and Pilot stages).
Answers to the open call application form will be instrumental to support the
decision on which beneficiaries are the best fit to BlockStart program

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format, images/schemes in some cases

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

Applications through F6S platform (  _www.f6s.com/blockstart_ )  , contacts
resulting from consortium members’ networks, desk research of contacts
publicly available online or interactions within the project’s activities
(e.g.: events)

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

**Archiving and storage:**

</td>  
<td>

F6S platform (  _www.f6s.com/blockstart_ )  
</td> </tr>  
<tr>  
<td>

**Data sharing policy:**

</td>  
<td>

Mixed:

  * Public, shared in  _www.blockstart.eu_ :  DLT solutions portfolio (basic description about each project), Beneficiaries dataset (including list of entities who signed a sub-grantee contract and corresponding funding received) 

  

  * Internal, only shared within consortium members: applicants’/beneficiaries’ contacts 

  

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May 2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Open call applicants’ ratings

_Table 2 Open call applicants’ ratings:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-2

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

**Relevant work package(s):**

</td>  
<td>

WP2 Engage, WP3 Prototype, WP4 Pilot

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

**Description of the dataset:**

</td>  
<td>

Numerical and categorical ratings of the open call applications, based on the
criteria presented in the open call documentation

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

**Data utility:**

</td>  
<td>

Support the selection of BlockStart’s beneficiaries (DLT developers, SMEs and
external experts) by the consortium, Advisory Board and external experts
(except, obviously, in the process of selecting external experts)

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

**Type:**

</td>  
<td>

Generated

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 100MB)

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

**Origin:**

</td>  
<td>

Applications through F6S platform (  _www.f6s.com/blockstart_ )  
</td> </tr>  
<tr>  
<td>

**Archiving and storage:**

</td>  
<td>

F6S platform (  _www.f6s.com/blockstart_ )  
</td> </tr>  
<tr>  
<td>

**Data sharing policy:**

</td>  
<td>

Internal

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  SMEs data for Pilot developments

_Table 3 Dataset SMEs data for Pilot developments:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-3

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

**Relevant work package(s):**

</td>  
<td>

WP4 Pilot

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

**Description of the dataset:**

</td>  
<td>

Data provided by the beneficiary SMEs

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

**Data utility:**

</td>  
<td>

Enabling the development of pilots by the DLT developers, in order to meet SME
needs

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Medium (approximately 500MB per SME)

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

**Origin:**

</td>  
<td>

Data provided by beneficiary SMEs

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

**Archiving and storage:**

</td>  
<td>

Dedicated spreadsheet in project’s Google Drive (accessible only to consortium
members and to the DLT developer creating the pilot development related to the
SME)

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

**Data sharing policy:**

</td>  
<td>

Internal

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Entities potentially interested in Ideation Kick-off

_Table 4 Dataset Entities potentially interested in Ideation Kick-off:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-4

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

**Relevant work package(s):**

</td>  
<td>

WP3 Prototype

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

**Description of the dataset:**

</td>  
<td>

Name, entity, professional contacts and justification of intention to
participate in BlockStart’s Ideation Kick-offs by DLT experts, investors,
SMEs, corporates, industry associations and other types of intermediaries

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

**Data utility:**

</td>  
<td>

Database of people potentially interested in participating in BlockStart’s
Ideation Kick-offs, enabling the consortium to define who will be able to
attend each event, and send the corresponding invitations

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

Declarations of interest through  _www.blockstart.eu_ ,  project’s social
media and profile at F6S platform

( _www.f6s.com/blockstart_ )  , contacts resulting from consortium members’
networks, desk research of contacts publicly available online or interactions
within the project’s activities (e.g.: events)

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

**Archiving and storage:**

</td>  
<td>

Dedicated spreadsheet in project’s Google Drive (accessible only to consortium
members)

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

**Data sharing policy:**

</td>  
<td>

Internal

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Entities potentially interested in Demo Day

_Table 5 Dataset Entities potentially interested in Demo Day:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-5

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

**Relevant work package(s):**

</td>  
<td>

WP4 Pilot

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

**Description of the dataset:**

</td>  
<td>

Name, entity, professional contacts and justification of intention to
participate in BlockStart’s Demo Days by DLT experts, investors, SMEs,
corporates, industry associations and other types of intermediaries

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

**Data utility:**

</td>  
<td>

Database of people potentially interested in participating in BlockStart’s
Demo Days, enabling the consortium to define who will be able to attend each
event, and send the corresponding invitations

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

Declarations of interest through  _www.blockstart.eu_ ,  project’s social
media and profile at F6S platform

( _www.f6s.com/blockstart_ )  , contacts resulting from consortium members’
networks, desk research of contacts publicly available online or interactions
within the project’s activities (e.g.: events)

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

**Archiving and storage:**

</td>  
<td>

Dedicated spreadsheet in project’s Google Drive (accessible only to consortium
members)

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

**Data sharing policy:**

</td>  
<td>

Internal

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May 2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Entities potentially interested in DLT Assessment tool

_Table 6 Dataset Entities potentially interested in DLT Assessment tool:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-6

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

**Relevant work package(s):**

</td>  
<td>

WP2 Engage

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

**Description of the dataset:**

</td>  
<td>

Name, entity and professional contacts of people potentially interested in
using and/or disseminating the DLT Assessment tool. Submissions through the
DLT Assessment tool (by SMEs)

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

**Data utility:**

</td>  
<td>

Enrich the database of SMEs eligible to participate in the Prototype and/or
Pilot stages of BlockStart. Involve intermediaries who, by disseminating the
DLT Assessment tool, will contribute to increase the knowledge on the uses of
DLT, while also helping BlockStart to reach out to further SMEs (who may turn
into potential participants in Prototype and/or Pilot stages of the program,
or even future clients of the portfolio of DLT developments)

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

Submissions on the DLT Assessment tool (probably to be held on Typeform),
declarations of interest through  _www.blockstart.eu_ ,  project’s social
media and profile at F6S platform  ( _www.f6s.com/blockstart_ )  , contacts
resulting from consortium members’ networks, desk research of contacts
publicly available online or interactions within the project’s activities
(e.g.: events)

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

**Archiving and storage:**

</td>  
<td>

Typeform (probably), dedicated spreadsheet in project’s Google Drive
(accessible only to consortium members)

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

**Data sharing policy:**

</td>  
<td>

Internal

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Open call webinars participants and recordings

_Table 7 Dataset Open call webinars participants and recordings:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-7

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

**Relevant work package(s):**

</td>  
<td>

WP2 Engage

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

**Description of the dataset:**

</td>  
<td>

Name and professional email of people interested in watching the webinars, and
video recording of the webinars

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

**Data utility:**

</td>  
<td>

Professional contacts are needed to share the weblink allowing access to the
webinar. The video recording of the webinars will enable people/entities
potentially interested to discover more about the program in more convenient
times (and not necessarily when it is streamed live)

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

**Type:**

</td>  
<td>

Collected and Generated

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

**Nature:**

</td>  
<td>

Text and video format

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

**Scale:**

</td>  
<td>

Small for text (approximately 10MB). Medium for video (approximately 50GB)

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

**Origin:**

</td>  
<td>

Registrations in webinars throug  h a  dedicated page for the event at the F6S
platform  ( _www.f6s.com/blockstart_ )  . Recording of open call webinars

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

**Archiving and storage:**

</td>  
<td>

Dedicated private area in BlockStart’s F6S account for name and email of
participants (accessible only to consortium members). Video recording
published in BlockStart’s public YouTube channel

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

**Data sharing policy:**

</td>  
<td>

Mixed (name and email of participants only shared within consortium members,
video recordings publicly available)

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Intermediaries training participants and recordings

_Table 8 Dataset Intermediaries training participants and recordings:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-8

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

**Relevant work package(s):**

</td>  
<td>

WP5 Impact

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

**Description of the dataset:**

</td>  
<td>

Name and professional email of people interested in watching the webinars, and
video recording of the webinars

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

**Data utility:**

</td>  
<td>

Professional contacts are needed to share the weblink allowing access to the
webinar. The video recording of the webinars will enable intermediaries
potentially interested to discover more about DLT in more convenient times
(and not necessarily when it is streamed live)

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

**Type:**

</td>  
<td>

Collected and Generated

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

**Nature:**

</td>  
<td>

Text and video format

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

**Scale:**

</td>  
<td>

Small for text (approximately 10MB). Medium for video (approximately 50GB)

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

**Origin:**

</td>  
<td>

Registrations in webinars throug  h a  dedicated page for the event at the F6S
platform  ( _www.f6s.com/blockstart_ )  . Recording of webinars

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

**Archiving and storage:**

</td>  
<td>

Dedicated private area in BlockStart’s F6S account for name and email of
participants (accessible only to consortium members). Video recording
published in BlockStart’s public YouTube channel

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

**Data sharing policy:**

</td>  
<td>

Mixed (name and email of participants only shared within consortium members,
video recordings publicly available)

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May 2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Policy workshops participants and recordings

_Table 9 Policy workshops participants and recordings:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-9

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

**Relevant work package(s):**

</td>  
<td>

WP5 Impact

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

**Description of the dataset:**

</td>  
<td>

Name and professional email of people interested in watching the webinars, and
video recording of the webinars

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

**Data utility:**

</td>  
<td>

Professional contacts are needed to share the weblink allowing access to the
webinar. The video recording of the webinars will enable policymakers and
other relevant people/entities potentially interested to discover more about
DLT in more convenient times (and not necessarily when it is streamed live)

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

**Type:**

</td>  
<td>

Collected and Generated

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

**Nature:**

</td>  
<td>

Text and video format

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

**Scale:**

</td>  
<td>

Small for text (approximately 10MB). Medium for video (approximately 50GB)

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

**Origin:**

</td>  
<td>

Registrations in webinars throug  h a  dedicated page for the event at the F6S
platform  ( _www.f6s.com/blockstart_ )  . Recording of webinars

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

**Archiving and storage:**

</td>  
<td>

Dedicated private area in BlockStart’s F6S account for name and email of
participants (accessible only to consortium members). Video recording
published in BlockStart’s public YouTube channel

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

**Data sharing policy:**

</td>  
<td>

Mixed (name and email of participants only shared within consortium members,
video recordings publicly available)

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Advisory Board members

_Table 10 Dataset Advisory Board members:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-10

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

**Relevant work package(s):**

</td>  
<td>

WP2 Engage, WP3 Prototype, WP4 Pilot, WP5 Impact

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

**Description of the dataset:**

</td>  
<td>

Name, professional contacts and specialization of the Advisory Board members

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

**Data utility:**

</td>  
<td>

Database of experts who will help the consortium in the definition of the open
call sectors, in selection and evaluation of applicants (DLT developers, SMEs
and external experts) for the Ideation Kickoff, Prototype and Pilot, and by
giving strategic counseling regarding other project’s activities (e.g.:
dissemination, trainings)

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

BlockStart’s Grant Agreement. New members may be added to the Advisory Board,
coming from the consortium members’ networks, or resulting from interactions
within the project’s activities (e.g.: events)

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

**Archiving and storage:**

</td>  
<td>

Dedicated spreadsheet in project’s Google Drive (accessible only to consortium
members)

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

**Data sharing policy:**

</td>  
<td>

Mixed (name, entity, role and LinkedIn profile of each Advisory Board member
shared in  _www.blockstart.eu_ ,  contacts only shared within consortium
members)

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Sector analysis participants

_Table 11 Dataset Sector analysis participants:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-11

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

**Relevant work package(s):**

</td>  
<td>

WP2 Engage

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

**Description of the dataset:**

</td>  
<td>

Name, professional contacts and specialization of experts in DLT and/or
industry sectors

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

**Data utility:**

</td>  
<td>

Experts who help the consortium in the analysis supporting the definition of
open call sectors

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

Advisory Board members (dataset BS-10) and other DLT/industry experts coming
from the consortium members’ networks or resulting from interactions within
the project’s activities (e.g.:

events)

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

**Archiving and storage:**

</td>  
<td>

Dedicated spreadsheet in project’s Google Drive (accessible only to consortium
members)

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

**Data sharing policy:**

</td>  
<td>

Internal

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

##  Sector-specific DLT maturity assessments participants

_Table 12 Dataset Sector-specific DLT maturity assessments participants:_  
  
<table>  
<tr>  
<th>

**Dataset reference:**

</th>  
<th>

BS-12

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

**Relevant work package(s):**

</td>  
<td>

WP5 Impact

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

**Description of the dataset:**

</td>  
<td>

Name, professional contacts and specialization of experts in DLT and/or
industry sectors

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

**Data utility:**

</td>  
<td>

Experts who will provide insights relevant to the assessment of Sector-
specific DLT maturity

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

**Type:**

</td>  
<td>

Collected

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

**Nature:**

</td>  
<td>

Mainly text format

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

**Scale:**

</td>  
<td>

Small (approximately 50MB)

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

**Origin:**

</td>  
<td>

Experts willing to participate, including Advisory Board members, DLT
developers, SMEs, investors and intermediaries (namely within datasets BS-1,
BS-4, BS-5, BS-6, BS-8, BS-10 and BS-11)

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

**Archiving and storage:**

</td>  
<td>

Dedicated spreadsheet in project’s Google Drive (accessible only to consortium
members)

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

**Data sharing policy:**

</td>  
<td>

Mixed (name, entity and role of participant may be included in the reports if
that reference is expressly authorized. Contacts only shared within consortium
members)

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

**Preservation time:**

</td>  
<td>

Until the end of the project (February 2022). Data needed to answer to
potential audits by the European Commission services may be kept for up to 5
years after the end of the Project (May

2027)

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

**Additional preservation cost:**

</td>  
<td>

None

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

#  Security

Taking into account the state of the art, the costs of implementation and the
nature, scope, context and purposes of processing as well as the risk of
varying likelihood and severity for the rights and freedoms of natural
persons, the BlockStart Consortium partners will implement and ensure
appropriate technical and organisational measures to ensure a level of
security appropriate to the risk, namely, personal data will be, to the extent
possible and necessary, anonymised in order to transform it in ordinary data
(non-personal data) and, as such, be statistically compiled for the purpose of
the project.

To prevent unauthorised access to personal data or the equipment used for
processing personal data, following security measures will be implemented:

  * all personal data will be safely stored in the password-protected accounts of the F6S platform where the data is held (following F6S data-related policies:  _www.f6s.com/privacypolicy_ ; _www.f6s.com/terms_ ; _www.f6s.com/data-security_ ; _www.f6s.com/cookie-policy_ ;  _www.f6s.com/cookie-table_ )  , and other online platforms (e.g: Typeform for the DLT Assessment Tool, Zoom for the webinars). In any circumstance, all personal contacts stored in whichever platform (always password-protected) will only accessible by people from the consortium working in the scope of BlockStart project; 

  

  * no personal data should be locally stored in any computer disk; 

  

  * all computers must be protected (only accessible through fingerprint or password). 

  

Moreover, the BlockStart platforms/repository can only be accessed, upon
request, by members of the Project consortium. The emails of the person
requesting access must be listed in the project staff. If the status of a team
member is changed to “not involved” or similar, the access will be revoked. By
revoking access, the system can only automatically ensure that the person will
not have access to the contents of the platforms/repository. It is not
possible to ensure that documents or data that have been downloaded are
deleted.

In order to prevent data breaches in case of theft of any of the tools used to
access the BlockStart repository, all team members are requested to minimize
the number of documents downloaded. Additionally, all team members are invited
to adopt appropriate security measures to protect computers, laptops, mobile
phones and similar tools to prevent unauthorized access in case of leaving the
tool unattended or in case of loss or theft.

#  Ethics

The personal data processing operations to be carried out under this project
are not subject to opinions and/or approvals by ethics committees and/or
public authorities, but merely subject to compliance with applicable legal
framework related to personal data protection (namely, GDPR).

#  Further clarification

Information on BlockStart’s personal data protection policy may be found at
_www.blockstart.eu/dataprotection/_ .

#  Conclusion

The current Data Management Plan aimed to present the principles and measures
the consortium will adopt to ensure the compliance of BlockStart’s prospective
data flows with legislation on personal data protection.

Starting with the purpose of personal data processing, it will be strictly
limited to the execution of the Project’s activities included in the
respective Grant Agreement’s Work Packages, and no personal sensitive data
will be collected.

To enable communication within BlockStart’s scope, a dataset will be created
including the professional contacts of data subjects working for and/or
representing the participant entities. It will mostly consist of emails from
DLT developers, SMEs, DLT experts, intermediaries and policymakers. Only the
Consortium parties will have access to the said personal data and, within the
Consortium parties organizations, only those strictly with a need to know
basis.

The gathered personal data will be deleted the earliest possible, in
accordance with the BlockStart activities and the applicable criteria and
requirements resulting from the applicable personal data protection laws,
namely, the GDPR. If it is absolutely needed, it may be kept until the end of
the project (February 2022) or, if the data happens to be needed to answer
potential audits, up to 5 years after the end of the project (prospectively
May 2027).

Among the principles to be followed by the consortium on data processing are
included data minimization, compliance with national and European legislation,
data subject information procedures, right to access and correct personal data
and, whenever possible, the anonymization/pseudonymization of personal data.

In order to prevent unauthorised access to personal data or the equipment used
for processing personal data, several security measures will be implemented
all throughout the Project by the consortium parties, namely the storage of
personal data in password-protected accounts of F6S platform.

BlockStart’s data flows and datasets resulting from the activities developed
within the Project’s Work Packages (with special emphasis in Engage,
Prototype, Pilot and Impact) were also explained in detail in this
deliverable.

This document will be updated in two occasions, in order to incorporate the
lessons learned from the first open call (month 16 – December 2020) and the
second and third open calls (month 28 – December 2021).