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  • Policy on retention and use of personal data

    Purpose

    This policy establishes the principles, responsibilities and approach for ensuring EIDC meets the requirements of the UKRI Privacy Notice, the CEH Privacy Policy, the NERC Data Protection Policy and the EIDC Privacy Notice which sets out the approach for handling personal information in accordance with the Data Protection Act 1998 and its successor, the General Data Protection Regulation (EU) 2016/979 (GDPR).

    The policy also supports the EIDC Acquisition Policy and aligns with the NERC Data Policy.

    Definition of personal data

    Personal data is here defined, as per the Data Protection Act and GDPR, as any information that can be used to identify a living individual.

    The Data Protection Act and GDPR stipulate that personal data held by organisations should be accurate, kept up-to-date, can only be used for the purposes stated at the time of collection and must be held for no longer than necessary, i.e. for only as long as it is being used.

    It gives no guidance on what is an appropriate length of time to elapse before an inactive user account should be considered for deletion.

    Scope

    This document only relates to personal data collected as part of the EIDC's scientific data management activities.

    Introduction

    The policy applies to all personal data collected, used, maintained and disseminated by EIDC.

    Personal data related to scientific data management.

    EIDC's specific responsibility for the handling of personal data pertaining to scientific data management has been divided into the following three categories:

    1. Personal information collected from users to enable access to EIDC's data holdings:

    • During automated requests handling on the public EIDC web site
    • During manual requests handling by EIDC staff

    The management of user personal data will be in accordance to a user's data protection rights, be sympathetic to the Data Originator's attribution rights and satisfy EIDC's business needs.

    EIDC will ensure that information is accurate and secure, and is not kept longer than necessary.

    2. Personal information collected to provide provenance for scientific data deposited with EIDC for safekeeping.

    This includes information relating to individuals involved at some point in the data lifecycle. For example during data collection, data processing, data distribution or governance. It covers a variety of roles such as data originators, EIDC staff, Principal Investigators (PI), data governors and project participants.

    3. Personal information collected to develop and agree plans with NERC grant holders to deposit scientific data they generate with NERC Data Centres for safekeeping.

    This includes information relating to individuals involved at some point in the data lifecycle. For example during data collection, data processing, data distribution or governance. It covers a variety of roles such as data originators, Principal Investigators (PI), data governors and project participants.


    1. Personal data relating to users accessing EIDC's data holdings

    Purpose of user data (automated and manual requests handling)

    The purposes for this personal data are:

    • To record agreement with a specified licence for each EIDC dataset accessed.
    • To notify the user of a secure link to access the data
    • To notify the user in the event of problems encountered during data delivery.
    • To notify the user in the event of changes to the data supplied.
    • To produce anonymised performance statistics

    Collection of user data

    The registration of users on the public EIDC data catalogue

    The purposes for the personal data will be directly communicated during the registration process and will also be available on the EIDC public website as part of EIDC's Privacy Policy.

    The registration process will discourage children (defined in the GDPR as under the age of 13), so that EIDC do not need to gain parental consent for the processing of children's personal data.

    The wording will be such that continuation with the registration process is the means whereby active consent is gained for the processing of personal data.

    Online ordering of data products

    The purposes for the personal data will be communicated directly during the order process and will also be available on the EIDC public website as part of EIDC's Privacy Policy.

    The order process will discourage children (defined in the GDPR as under the age of 13), so that EIDC do not need to gain parental consent for the processing of children's personal data.

    The wording will be such that continuation with the order is the means whereby active consent is gained for the processing of personal data.

    Manual requests handling

    The purposes for the personal data collected during the processing of a manual request will be communicated to the data user via email and will also be available on the EIDC public website as part of EIDC's Privacy Policy.

    To satisfy active consent the data user will need to email a reply to say they agreed to the processing of their personal data.

    Access to user data

    Data management activities

    Access to user personal data held at EIDC will be restricted to authorised EIDC individuals as required by their role. This will be limited to the information they need to fulfil their duties.

    Information for Key Performance Indicators

    Personal data relating to user transactions will be used in the compilation of annual performance reports, which will be kept indefinitely. Any statistical data presented within these performance reports, when based on personal data, will be anonymised.

    Dissemination outside of EIDC

    No personal data will be shared with third parties.

    Accuracy of information

    The onus falls on the user to keep their information up-to-date. This expectation will be explicitly stated during all communications. It will also be made available via EIDC's Privacy Policy on the EIDC public web site.

    Users will have the ability to

    • inform EIDC of changes to their personal details via the EIDC public web site

    During the manual requests process it is the responsibility of the person requesting data, information or products to notify the EIDC Requests Team of any change of status. Provenance will be maintained for historic requests so the change will only apply to subsequent requests.

    Following the receipt of a verifiable notification of change of status, members of the EIDC are responsible for responding to and acting on (within two working days) the notification that a registered user has changed their details.

    If the notification has been received through the project route, the EIDC Project Data Managers have responsibility to relay information to the EIDC Requests Team.

    Retention of user data

    Requested removal of user accounts

    Following a verified request for the removal of a user account:

    • If no data have been downloaded, the user's account will be deleted.
    • Personal information will be maintained for all download activities as this forms an audit trail of the licence terms agreed for the dataset.
    Inactivity of users' accounts
    If no data have been downloaded, users' accounts will be deleted after a period of 10 years of inactivity.
    Manual request handling

    On request, user data collected during the process of servicing a manual request or distributing a data product will be anonymised.


    2. Personal data relating to the provenance of scientific data

    Purpose of provenance data

    The purposes for this personal data are:

    • To tag scientific data as part of the data management processes to support the transparency and integrity of the research process and if necessary, provide additional information to enable data re-use and re-purposing.
    • To facilitate data citation through the assignment of Digital Object Identifiers.
    • To provide a point of contact for use by the EIDC Management to raise or respond to questions concerning the data or metadata.

    Provenance data relate to individuals involved at some point in the scientific data lifecycle. This could be during collection, processing, distribution or governance. Examples include Principle Investigators (PI), data originators, Principle Scientific Officers (PSO), data governors, project participants and EIDC staff.

    Collection of provenance data

    The purposes for the personal data will be communicated to the data provider during the submission of data (and metadata) and will also be available as part of the EIDC Data Deposit Conditions on the EIDC public web site.

    As these individuals will not be children, the issue of parental consent for the processing of personal data does not arise.

    The wording will be such that continuation of a data/metadata deposit is the means whereby active consent is gained for the processing of personal data.

    Access to provenance data

    In the interests of maintaining and supporting the integrity and transparency of the scientific research process, it is common practice within the scientific publications for attribution to be included. In accordance with this, personal information relating to the provenance of Open scientific data will be in the public domain.

    Accuracy of information

    The onus falls on the data provider to keep their information up-to-date and this expectation will be explicitly stated during all communications. It will also be made available via the EIDC Data Deposit Conditions on the EIDC public web site.

    Data providers will have the ability to

    • inform EIDC of changes to their personal details via the EIDC public web site
    • inform EIDC of changes of their role via the EIDC public web site

    Following the receipt of a verifiable notification of change of status, the EIDC are responsible for responding to and acting on the notification that a data provider has changed their details and/or role.

    Retention of provenance data

    Provenance data will be kept indefinitely for scientific data governance purposes.


    3. Personal data relating to NERC grant holders Data Management Plans

    Purpose of provenance data

    The purposes for this personal data is to develop and agree plans with NERC grant holders a Data Management Plan to deposit scientific data they generate from a specific grant with NERC Data Centres (or agreed alternatives) for safekeeping.

    This includes information relating to individuals involved at some point in the data lifecycle. For example during data collection, data processing, data distribution or governance. It covers a variety of roles such as data originators, Principal Investigators (PI), data governors and project participants.

    Collection of grant data

    Personal data of the NERC grant holder will be securely accessed and copied by EIDC adminstration staff from the NERC grants administration portal and held on secure EIDC administration systems. The purposes for the personal data will be communicated to the data provider during the initial communication with the Principal Investigator and will also be available on the EIDC public web site.

    As these individuals will not be children, the issue of parental consent for the processing of personal data does not arise.

    The wording will be such that continuation of a data/metadata deposit is the means whereby active consent is gained for the processing of personal data.

    Access to NERC grant data

    No personal information relating to the NERC grant will be shared to third parties..

    Accuracy of information

    The onus falls on the grant holder to keep their information up-to-date and this expectation will be explicitly stated during all communications.

    Data providers will have the ability to

    • inform EIDC of changes to their personal details via direct email communication with EIDC
    • inform EIDC of changes of their role via direct email communication with EIDC

    Following the receipt of a verifiable notification of change of status, the EIDC are responsible for responding to and acting on the notification of a change in details and /or role.

    Retention of NERC grant data

    NERC grant data will be kept indefinitely for audit trailing of agreed data plans as part of the grant evidence of meeting grant conditions.

    Policy ownership

    The Head of EIDC owns this EIDC Policy.

    Policy review

    The EIDC Management Group will review the policy annually or sooner if required by changes in the governance, legal or contract obligations of the EIDC.