#  I. Context for an InsSciDE Data Management Plan (DMP)

As a publicly funded H2020 project InsSciDE is required to submit, within its
first six months, a Data Management Plan to aid compliance with the Open
Research Data Pilot (ORDP). That pilot "aims to make the research data
generated by Horizon 2020 projects accessible with as few restrictions as
possible, while at the same time protecting sensitive data from inappropriate
access"  1  . The ORDP 'follows the principle " _as open as possible, as
closed as necessary_ " and focuses on encouraging sound data management as an
essential part of research best practice.'  2

InsSciDE moreover works with human subjects, meaning that the data generated
by our project includes personal information – which is explicitly protected
by the General Data Protection Regulation (GDPR) coming into force in May
2018.

The InsSciDE Data Management Plan (DMP) therefore addresses pragmatic, ethical
and legal questions that arise as we consider to what extent and how the data
we collect can be "free to access, reuse, repurpose, and redistribute"  1  .

This first draft of the DMP targets the main questions identified at the time
of settling the Grant Agreement, in light notably of the Ethics Report
submitted by proposal reviewers. As deliverable 10.2a it will be reviewed,
improved and updated in line with the first Project Review at 12 months.

#  II. Essential procedures – quick summary

InsSciDE researchers and other staff must observe several obligations when
they collect, store, delete, or otherwise process **personal data** ( _any
information relating to an identified or identifiable natural person)_ for
project uses. _Each member of InsSciDE should consider herself personally_
_responsible for meeting these obligations_ :

  * in light of European law and regulations and 

  

  * in light of ethical standards and standards observed in the research discipline. 

  

_The WPL ensures that CSA and staff have been correctly informed of
obligations._ InsSciDE recognizes that different members of the project may
make different disciplinary or ethical claims. However, _all_ _commit to
observing at least the basic standard_ which is described in this Data
Management Plan and in the project Information sheet and Consent form. All
members can initiate discussion within the InsSciDE community, or request WPL
or Coordinator guidance, to clarify obligations and standards.

According to law, individuals in Europe always have the right to gain access
upon request to all their personal data which might be stored by a business or
other institution, to be informed about the processing of this personal data,
to rectify inaccurate personal data, and to oppose its further processing. _To
exercise these 'data rights'_ , every person easily learns the name and
contact email of InsSciDE officials from our public communications, website,
Information sheet, Consent form etc.

##  **Interview data**

_Interviewees must give their active and informed consent before an interview
can take place._  
  
<table>  
<tr>  
<th>

  * InsSciDE provides a project Information sheet on our public website where it can be consulted by the prospective interviewee. 

  

  * Basic templates of the Sheet and Form are available from the WPL or from the project intranet. In agreement with the WPL, _each researcher adapts the Information sheet and the Informed consent form to her specific needs and ethical commitments_ . 

  

  * Before the interview, when meeting the person, the researcher provides a print out of this adapted Sheet and two copies of the Informed consent form and answers any questions. 

  

  * _To give consent the interviewee signs both copies of the Consent form. The researcher acknowledges her commitments by countersigning both copies._ The interviewee keeps one copy of the signed Form. 

  

  * _The researcher stores the remaining copy of the signed Form and identifies and stores the audio recording according to safe procedures set by her own institution, and fills out the InsSciDE Monitoring Tool to confirm that the consent form was signed and archived._ The (anonymisable) Monitoring Tool will be developed as part of D10.4_Quality templates. 

  

  * InsSciDE plans to deposit interview recordings at the Historical Archives of the EU after the close of the project. _The interviewee can opt IN to this central archiving on the Consent form._

  

_The researcher can opt OUT at the close of the project._

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

##  **Mailing list and administrative data**

Our mailing lists are composed of persons who have _opted in, either by
registering directly with the_ _project or by expressing interest in InsSciDE,
its activities, or science diplomacy_ . _All persons can opt_ _out_ through a
link provided in our digital newsletters and other communications.

_We restrict access to personal data_ collected for mailing lists and other
administrative purposes, and _destroy centralized data listings when they are
no longer needed for InsSciDE_ (as early as possible and at the latest 2
months after the end of the project, unless other rules override).

Project members need not destroy mailing lists that they build up during
InsSciDE. However they _commit to continue beyond the project lifetime to
respect data protection obligations and persons'_ _data rights_ , notably by
using the lists only for scientific purposes and by offering opt-out links.

#  III. Features and procedures of the InsSciDE DMP

Guidance  3  suggests that an H2020 DMP should describe

  * The data set. _What kind of data will the project collect or generate, and to whom might they be useful later on?_

  

  * Standards and metadata. _What disciplinary norms are adopted in the project? What is the data about? Who created it and why? In what forms it is available?_

  

  * Data sharing. _By default as much of the resulting data as possible should be archived as Open Access; which are legitimate reasons for not sharing resulting data?_

  

  * Archiving and preservation. _How will data be made_ _available for a suitable period beyond the life of the project to ensure that publicly funded research outputs can have a positive impact on future research, for policy development, and for societal change?_

  

D10.2a covers each of these points in a preliminary way, detailing some
project procedures and also some archiving opportunities. In particular **we
describe below the data protection responsibilities of InsSciDE researchers.**

##  **Which data are concerned? Which objectives are sought in managing the
data?**

InsSciDE involves human participants:

  1. **who are volunteers** for research in the social sciences or humanities, including persons interviewed for historical case studies or oral histories ; participants in public or other project events ; _and/or_

  

  2. **who consent** to provide contact data to be stored in the form of mailing lists for specific project activities and dissemination. 

  

  

The project does not involve children or others unable to give consent.

In light of participation by human subjects certain ethical obligations ensue.
InsSciDE consortium partners recognize the need to carry out all the work in
our project to the highest ethical standards in full compliance with relevant
international, national and local legislation, regulations and codes of
conduct. In our practical research context these standards address in
particular the need to respect the volunteer participants’ right to
confidentiality and control over their **personal data** (see Box 1).

####  Box 1 – What does 'personal data' mean?

Under EU law (the General Data Protection Regulation which comes into force 25
May 2018), personal data means _any information relating to an identified or
identifiable natural person_ ('data subject'). An identifiable natural person
is one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number, location
data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that
natural person. It doesn’t have to be confidential or sensitive to qualify as
personal data.

Current European legislation requires the **active consent** of persons to
share their data. The GDPR mandates requirements for **collection, storage,
deletion and other processing of personal data** . This applies notably to
personal data stored by **digital** means; InsSciDE researchers and other
staff are attentive also to the proper treatment of **paper** records, as well
as respect for confidentiality in their **conversations and exchanges taking
place by any means** .

InsSciDE data management procedures should support us in properly respecting
our participants’ **data rights.** They should help us judiciously meet
obligations related to our being part of the Open Research Data Pilot, which
aims to make data findable, accessible, interoperable and reusable (FAIR). The
same management procedures should provide pragmatic solutions acceptable in
light of **disciplinary standards** in the social sciences and humanities
(including history, science technology and society STS studies, media studies,
political science, etc.) as diversely claimed by our researchers.

It is recognized that while our project is by default part of the ORDP, "there
are good reasons to keep some or even all research data generated in a project
closed"  4  and therefore the Commission offers robust opt-out procedures.
Good reasons for InsSciDE researchers to opt out include:

  * respect for overriding legal obligations to protect privacy and confidentiality of the persons who consent to be interviewed, and/or 

  

  * researchers' interpretation of their ethical commitment according to their personal or disciplinary standard (which shall not be lower than the standard expressed in the project Information sheet or Informed consent form D11.1.2). 

  

The rationales for both open data sharing and data protection are reviewed in
an infographic provided by H2020, annotated by InsSciDE (Annex 1).

##  **Who is responsible for protecting InsSciDE participants’ data rights?**

The H2020 Grant Agreement n°770523 signed by InsSciDE consortium partners
stated that: _Each [consortium partner] shall be responsible to ensure that
their researchers operate within their national legislation and comply with
their relevant national ethical guidelines_ .

However this DMP proposes that in acquitting their ethical commitment,
**InsSciDE staff shall observe the principle of subsidiarity** , as adapted to
project management: that is, ‘ _a central authority should have a subsidiary
function, performing only those tasks which cannot be performed at a more
local level_ ’ (Oxford English Dictionary). In practice this means:

  * **Each staff member takes personal responsibility for ensuring, at her own level, respect for the data rights of the InsSciDE participants with whom she is in contact** : persons interviewed for historical case studies or oral histories ; participants in public or other project events ; persons sharing their data for social or traditional media uses (e.g., subscribing to the project mailing list). 

  

  * In order to carry out this personal responsibility, each staff member may **refer for help or guidance to the next higher organizational level** : her Work Package Leader, the project Coordination, or relevant officials at her place of employment (in particular, the Data Protection Officer appointed at latest on 25 May 2018 under European legislation). _In all cases it is advised to keep the WPL informed of any issues or problems encountered._

  

  * A Work Package Leader can also ask for a point to be addressed at the next meeting of the project Management Board. 

  

  * The Coordination can consult, in case of need, the European Union Research Programme Officer and/or members of the project Advisory Board. 

  

  * As regulated by the Consortium Agreement, the Consortium Assembly may be asked to deliberate in case of need. 

  

This DMP, and subsequent drafts, intend to foster subsidiarity by providing
guidance and procedures applicable by all.

All participants submitted to the Coordination copy of their institutional
ethical guidelines relevant to volunteer human participation in social
sciences or humanities research and contact information for the Data
Protection Officer. These texts, or the link to the public online access point
for these texts or instructions to request them from the Coordination, appear
in Annex 2.

##  **Project Procedures and Deliverables**

The Coordination develops and oversees procedures to ensure the proper
integration and observance of H2020 guidance and European and national ethical
requirements on research with human subjects and protection of personal data.
This is achieved through the following actions and resources:

  * D11.1.2_Consent Form and Project information sheet are updated templates developed with input from the project advisor D. Schlenker (Historical Archives of the European Union, HAUE) and the Management Board. The document containing instructions and the templates for adaptation by each researcher is available to all project partners through the Coordination, WPL and/or through the intranet. 

  

  * The Coordination will introduce a monitoring tool to control the actual collection of consent forms and their local or central archiving as appropriate. This tool is communicated as part of D10.4_Quality Templates and Administrative Procedures. 

  

  * In line with the fact that each consortium partner is ultimately responsible for the respect of legislation, Annex 2 provides access to each partner's institutional ethical guidelines relevant to volunteer human participation in research, and the contact for the Data Protection Office of each institution (the person who replies to any claims and who can provide information on facilities and practices for the protection of personal data). 

  

  * The Coordination ensures that the Management Board is fully informed of project requirements as well as the existence of European and institutional requirements and codes, and that the MB cascades their application to all concerned case study authors or other research or subcontracted personnel. This is formally achieved through the review of the present D10.2a and a first MB virtual meeting held on 27 April 2018\. 

  

  * The Coordination maintains communication with WPL to assess the application of policy regarding incidental findings that may emerge during interviews with diplomatic personnel, as well as overall compliance with the project Data Management Plan. 

  

  * Detailed information is kept by the Coordination in the project files on the informed consent procedures that will be implemented with regards to the collection, storage and protection of personal data (D11.1.2, Information sheet and Consent form templates). The observed procedures are made available on request to external parties and a notice to this effect is included on the public website. 

  

###  Qualitative interviews and oral histories

InsSciDE will conduct qualitative interviews and oral histories. Such
enquiries, traditional and widely practiced in social sciences and humanities
research, rely on the participation of volunteers who give their informed
consent. The purpose of conducting oral history is to have insights not easily
found in printed and published sources, providing the chance for a clearer
understanding of subjective interpretation as well as the recording of overall
(impersonal) facts and trends.

The qualitative research does not seek to access personal information but
rather deals with work culture and practices. The qualitative material and
personal data eventually collected in the course of this research will not be
subjected to any statistical treatment. The material collected will be
transformed into depersonalized InsSciDE study materials for open and closed
meetings, and into the finalized Case Study Library accessible to
professionals, scholars, teachers, students, and the interested public.

In order to obtain the informed consent of interview and oral history
subjects, the recruitment includes a procedure of providing information (
**D11.1.2** ) on the nature of the enquiry, the overall aims of InsSciDE, the
expected participation and means of recording qualitative input, and the uses
to which the information will be put, including the depersonalized character
of its transformation into project study materials and published case studies,
and finally the means by which consent may be withdrawn. The procedure also
informs the subject of measures that will be applied to protect personal data,
and the transparency procedures allowing access and rectification, etc. in
conformity with legislation. The recruitment is sealed by the signature of the
subject on an individual consent form which is countersigned by the researcher
and archived at the researcher institution and if appropriate or necessary by
the InsSciDE Coordination.

The procedural information, the content of the consent form, the approach to
processing collected qualitative input, its management, the protection of
personal data, and the identification in published materials of the role or
nature of the participants, are all framed by existing H2020 guidance and by
European legislation and codes (see the DMP Section III).

WPL are responsible for ensuring the necessary training of researchers to
correctly apply the procedures. Effective application is monitored by the
Coordination in liaison with the MB through the Monitoring Tool provided as
part of D10.4_Quality templates.

###  Handling of incidental findings

Incidental findings emerging from interviews are those which may reasonably be
judged sensitive in that they regard policy decisions and actions of
governmental organizations. The draft incidental findings policy (Box 2) takes
account of European ethical and security requirements on managing and
archiving research data.

####  Box 2 - Draft incidental findings policy  
  
<table>  
<tr>  
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Researchers performing interviews or collecting oral histories shall firstly
observe all data collection and management procedures as stipulated by the
partner institution, by the Consortium Agreement, by the project ethical
guidance and in the project Data Management Plan. **The latter includes
compliant procedures for data collection, storage, protection, retention and
destruction, and stipulates security measures for the case of incidental
findings of sensitive nature** . Partners are responsible for ensuring that
each researcher is properly instructed in the procedures and cognizant of the
personal responsibility these imply for research personnel.

The information provided to volunteer subjects in view of their consent shall
explain the project procedures concerning such potentially sensitive or
damaging content that could emerge in the course of interviews. These
procedures are briefly outlined here and may be **developed and formalized**
in light of experience.

  1. In the interview situation and afterwards, each researcher shall be vigilant with regard to the expression by the interview subject of incidental findings with security relevance (for example, but not limited to, information on policy decisions or government actions). At the start of each formal interview, recorded or not, the researcher shall remind the subject of the need to avoid disclosure of sensitive or damaging information. At the close of the interview the researcher will ask the subject whether any information provided during the interview should be redacted and/or requires the application of security measures. The researcher shall act in a timely manner on the reply received and shall alert the WPL that the procedure has been activated. 

  

  2. If, subsequent to the interview situation, in particular at the time of reviewing collected material, the researcher judges that incidental findings may be sensitive, the researcher will alert the WPL to the existence of such findings, and apply the security measures agreed in the Data Management Plan. In cases when the researcher is unsure of whether the information is of sensitive nature, a conservative decision shall be taken. 

  

  3. The WPL shall report all such alerts received to the Coordination in real time. The Coordination will log occurrences and include this statistic in periodic reporting. In case of concern, the WPL or Coordinator may request that the agenda of the quarterly Project Management Board virtual meeting include a point for discussion. At no time will any sensitive information itself be relayed or discussed. 

  

  4. Any data breaches are immediately reported by the involved partner in **compliance with the GDPR.**

  

  

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

The targeted subjects include diplomatic personnel, scientific and technical
experts. They will be recruited based on their expertise, experience, insight
and/or role in actual cases of scientific diplomacy as described in the
relevant case study abstracts of the InsSciDE project. It is expected that
most of the interviewees are bound by their contractual confidentiality
agreements with their employer and moreover that their professional experience
has educated them to the necessity of keeping sensitive information secret. In
general, expert researchers, postdoctoral researchers and graduate students
who may conduct InsSciDE interviews and oral histories will have no
relationship to their subjects outside of a research relationship.

###  Personal data protection

InsSciDE WP1 and WP9 have established opt-in databases of mailing list data
relative to stakeholder participants and persons who consent to receive the
newsletter and other project dissemination deliverables. The same persons are
enabled to opt out ('unsubscribe' link in each digital project newsletter, and
publication of contacts on the InsSciDE website).

Primary details of the procedures that implemented for data collection,
storage, protection, retention and destruction for the personal data collected
for dissemination mailing lists, confirmed as in compliance with national and
EU legislation, are displayed in Box 3.

####  Box 3 - Primary details of compliant procedures for data collection,
storage, protection, retention and destruction.  
  
<table>  
<tr>  
<th>



</th>  
<th>

Responsible person: The **responsible person in each partner organization** is
identified (or if necessary, assigned on project basis); see Annex 2.
**Contact information** for overall (Coordinationlevel) project data
controller and data protection officer is provided on the project **website**
: _contact@insscide.eu_

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



</td>  
<td>

Data collection: All personal data (generally limited to mailing-list type
information) is collected on an opt-in or consent basis using **transparent
web forms and/or paper coupons** . The inclusion of personal data (limited to
name, title, and institution) in public records of project activities,
deliverables or dissemination publications shall be **agreed by the person**
at the time of opt-in.

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



</td>  
<td>

Storage: **Database characteristics are submitted to the supervisory authority
in France and in Poland** (mailing list data storage partners’ domiciliation)
for validation if required by the prevailing legislation; otherwise prior
validations and public explanatory text in line with the law are relied on.

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



</td>  
<td>

Protection: Privacy by Design and by Default are applied.

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



</td>  
<td>

Retention: **Personal data specifically in the form of mailing lists shall not
be kept for longer than is necessary for the purpose of InsSciDE research and
dissemination activities** .

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



</td>  
<td>

Destruction: **Personal data in digital form, specifically information
provided by persons at the time of opting in to project mailing lists, shall
be erased by InsSciDE coordination within 2 months** of the close of the
project. When relationships have been established between researchers and
these persons, or between consortium partner institutions and these persons,
InsSciDE shall not seek to control or remove personal data managed by these
researchers and partners.

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

At present, the InsSciDE consortium cannot foresee any ethical implications
arising from results generated by the project (e.g. very limited potential for
dual use; no foreseen risks to rights and freedoms of consenting volunteers
and mailing list members, etc.) but in the **ongoing evaluation of outputs
they will take into account the opinions of e.g. the European Group on Ethics
in Science** and New Technologies (as from 1998). In case of need the
appropriate risk assessment and subsequent actions in light of the GDPR will
be applied.

###  Archiving and preservation of personal data

Each InSciDE partner institution has provided access to its ethical policy
(Annex 2) which alongside

European regulations governs the handling of research data containing personal
information.

InsSciDE researchers and staff take appropriate care to restrict access to
data stored locally in any form. Data no longer needed after the close of the
project is destroyed.

As for long term archiving and preservation of research data for the benefit
of European citizens and other researchers, InsSciDE accepts the invitation by
Advisory Board member Dieter Schlenker, HAEU to make a private project deposit
of interview recordings to the Historical Archives in Florence. Box 4 traces
the archiving discussion held at the first MB virtual meeting (27 April 2018)
with the participation of D. Schlenker, HAEU. The meeting addressed the
balance to be found between

  * the ORDP requirement to make research data "FAIR" (findable, accessible, interoperable and reuseable), and 

  

  * respect for legal and ethical commitments to confidentiality and privacy. 

  

The solution of archiving recordings and metadata at the HAEU, combined with
carefully tailored optin consent appears to offer a good balance.

####  Box 4: Making InsSciDE interview data FAIR: Findable Accessible
Interoperable & Reusable  
  
<table>  
<tr>  
<th>

The InsSciDE budget does not include funding for transcription of interviews,
so we discussed the preservation and reuse of audio recordings. Dieter
Schlenker of the Historic Archives of the European Union (HAEU) renewed his
invitation to preserve our material after the close of the project. This is
considered a "private deposit from a research group" and the HAEU places no
stipulations on format or content, including whether interviewees are
identified (oral histories) or anonymized. A written agreement stipulates how
the material is labeled, embargoed, etc. The depositor must fill a metadata
grid. It is not expected that depositors otherwise prepare the material for
the use of future researchers.

InsSciDE researchers may wish to create _chronothematic tables_ identifying
themes and the audio sequences in which they appear. These tables are
suggested for our own use and are not a requirement for deposit in HAEU.
However, InsScIDE WP3 formally requests that researchers facilitate the
exploitation of the interviews for this cross-cutting work package.
Researchers should signal any information uncovered by the interview about the
role of academies in science diplomacy, or about networks of science
diplomats.

The following questions were discussed with Dieter Schlenker during our MBM:

  1. **What do our interview subjects need to know about the opportunity for our interview recordings to be placed in the HAEU?**

  

  

The project Information sheet and Informed consent form clearly indicate this
opportunity and Dieter advises that we add a checkbox on the form to allow
interviewees to choose.

  1. _When would researchers who opt to do so, place recordings in the archives?_ After the close of the project and after the major scientific articles are published. 

  

  2. _When would the recordings become publicly accessible?_ Immediately after the HAEU inventory process, and according to the explicit instructions provided by the depositor who may choose to embargo the material for a further 1, 2 or 3 years in case new publications are anticipated. Longer embargos are not advised. 

  

  

  2. **What does "OFF THE RECORD" mean in this context?**

  

  

InsSciDE is conducting historical research, not looking for journalistic
scoops. After the end of the recorded interview the researcher asks the
interviewee if any aspects should be considered off the record. Some InsSciDE
researchers will explicitly provide an "off the record" option up front.

  1. _Should we turn off the recorder during the interview_ ? – It is certainly possible to do so to maintain the interviewee's confidence. Several InsSciDE researchers include this in their practice. 

  

  2. _Can we edit the recording before archiving it?_ – This is also possible but it represents some technical effort. Often archived recordings from other contexts contain exchanges which the interviewee identifies as off the record. The HAEU guidelines direct persons consulting the recording to respect this wish. 

  

  

  3. **What about copyright and intellectual property?**

    1. _Do H2020 researchers have to relinquish copyright on their data when they opt to archive it?_ Because 

  
  

  

  

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

we are not providing transcripts, we are advised that there is no need to
relinquish copyright to the archives (no copies will be made).

b) _What about intellectual property?_ The deposit will be made by InsSciDE,
and labeled accordingly. The researcher conducting each interview is
identified as the permanent holder of the intellectual property. The HAEU
guidelines for reuse stipulate that future researchers must cite the original
depositor and research owner.

**4\. What safeguards are applied by HAEU for reuse of the recordings?**

  1. _Ethical treatment for the interviewee_

  

  2. _Ethical treatment for the owner of the research= the InsSciDE researcher_

  

  

Dieter Schlenker will point us to the 5-page guidelines that HAEU gives to
researchers who consult recordings in the archives. Again, there are no
absolute controls but the guidelines state what is regarded as ethical
conduct. Although the archives are officially open to the public, the vast
majority of persons consulting the archives are professional researchers.
Occasionally journalists consult to gather information about famous
personalities to inform obituaries, or at anniversaries of major events.

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

#  IV. Relevant Legislation and Formal Documents

Some of the text below is adopted from the Grant Agreement n°770523 which
binds the consortium partners. It is included in the DMP in order to encourage
all InsSciDE staff to consult and consider the relevant regulations and codes.

###  European Union Regulations and Codes

When signing the Grant Agreement, all InsSciDE consortium partners committed
to respect all ethical requirements in project objectives, methodology and
practices. InsSciDE partners confirm that the ethical standards and guidelines
of Horizon2020, including those set out in The European Code of Conduct for
Research Integrity, Revised Edition, 2017  5  , will be rigorously applied,
regardless of the country in which the research is carried out.

The work in InsSciDE shall be performed in accordance with regulations at the
European level. The InsSciDE consortium committed to respect the following EU
legislation and regulations:

  * The Charter of Fundamental Rights of the European Union (2000/C 364/01) 

  

  * The European Convention on Human Rights as amended by Protocols Nos. 11 and 14 and supplemented by Protocols Nos. 1, 4, 6, 7, 12 and 13 

  

  * Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data 

  

  * General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) as of its application on 25 May 2018. 

  

Annex 2 provides the **contact information for the Data Protection Officer**
of each InsSciDE consortium partner. The InsSciDE Coordination keeps this
information on file in order to provide it immediately upon request to any
staff member or other participant in InsSciDE.

###  National Legislation

As confirmed by the Grant Agreement, in accordance with EC rules all the
personal data that will be collected or used in the InsSciDE project will be
duly treated, respecting legal and ethical requirements in obedience to the
legislation of data protection of the countries in which consortium partners
are legally established.

All research activities within the project shall be conducted in compliance
with the fundamental ethical principles and shall conform to current
legislation and regulations in the countries where the research is carried
out.

Mailing and attendance lists shall be processed in compliance with national
and project procedures to protect personal data.

###  Consortium Agreement

The Consortium Agreement signed by all InsSciDE partners including those
external to the European Union (4-UNESCO, 5-UiT in Norway,) contains a
requirement on observance of European standards of ethical treatment of social
sciences or humanities research subjects, and a requirement to respect the
provisions to be agreed in the present project DMP (D10.2).