How to handle personal data in research?

If you collect information from or of persons, assume that it is personal data. Also pseudonymised data is personal data.

If you collect personal data, do the following:

1. Plan what data you need

Understand the objectives of your study both now and in the future. Think about what data you need and also what data you do not need. Think of how you can design your study so that your data is least identifiable while still accomplishing your goals. These  data minimization and privacy by default principles  are core principles of  the General Data Protection Regulation (GDPR). More information on what is personal data can be found in:

2. Plan the entire life cycle of personal data processing

Plan the entire life cycle of personal data processing (including e.g. collecting, storing, usage, research cooperation, further research, archiving, deletion) before you begin to collect or otherwise process any personal data. Aalto’s privacy notice template can be used to help with this planning (please see the list item five below). A Data Management Plan can be used The Finnish national instructions on handling confidential and personal data can be used to support planning.

The Finnish Social Science Data Archive  FSD is a certified research data repository and they give expert advice on personal data in their research data management instructions.

3. Take care of data security and use Aalto University approved information systems

Ensure adequate security measures and use only Aalto University approved information systems. Review the security measures described on the pages linked below:

  • General instructions for secure processing of personal data, especially sections 3, 9, 11, 12 and Special Instructions 1 and 2.
  • Further information is on the page Cyber Security for research

General instructions for secure processing of personal data

These instructions contain the key issues related to the processing and data security of personal data.

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Use only approved IT systems to handle personal data. These services are good for most cases (expect for the sensitive personal data that needs extra security measures):

  • For Aalto internal projects: Teamwork folder with access restricted to project team members.
  • For projects with external collaboration: Eduuni workspace with access restricted to project team members.

Additional IT services are listed in Pikaohje tiedon luokittelemiseen. Systems approved for confidential ("luottamuksellinen") and secret ("salainen") data are suitable for personal data.

File storage space for research and groups (TeamWork)

Researchers, research groups and projects can use the specific TeamWork file service. Features are adjusted to meet the needs of each group.

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Eduuni - Teamwork environment

The Eduuni workspace includes Microsoft SharePoint workspaces for use by organisations, networks, projects and teams. Eduuni is used mostly for EU-wide, international research projects, because it enables cooperation also with parties outside of Aalto University. If the information stored is not confidential, it is advisable to use Microsoft Teams for teamwork.

General instructions for secure processing of personal data

These instructions contain the key issues related to the processing and data security of personal data.

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4. Evaluate risks to data subjects 

4.1 Get ethical pre-evaluation 

If sensitive personal data is processed in your research project, you must get an ethical pre-evaluation of Aalto Research Ethics Committee. Even in other cases a research partner,  publisher or funder may require ethical review. Lack of ethical review can prevent publishing or funding of the project.  

  • Sensitive personal data is special category data or data related to criminal records, social security number, bank account details.
  • Special category data is data concerning health or revealing political opinions, data which reveals racial or ethnic origin, religious or philosophical belief, trade union membership,  genetic data,  biometric data, when it is  processed for the purpose of unambiguous identification of a natural person, and data concerning sex behavior or sexual orientation.

4.2 Carry a data protection impact assessment (DPIA) when needed

Research Ethics Committee

Aalto University Research Ethics Committee is responsible for the ethical evaluation of  the university's non-medical research projects with human participants.


Ethical review of research and DPIA

Information when and how to prepare DPIA in research as an appendix for research ethics statement request

Kaksi henkilöä pöydän ääressä kirjojen ja kannettavien tietokoneiden kanssa.

5. Define the legal basis for processing personal data.

You can only process personal data if you have a legal basis provided in the legislation. In scientific research, the legal basis is usually either “performance of a task carried out in the public interest” or “consent”.

  • The choice of the legal basis is important, because it affects e.g. your obligations and possibilities in the research.
  • If purposes of the scientific research are in the public interest, it is advisable to use as legal basis "scientific research, a task in the public interest". However this legal basis is based on GDPR and national legislation, in EU projects involving other jurisdictions than Finland some universities  may use consent as legal basis.
  • If you choose “consent” as the legal basis for processing, you must e.g. enable the participants to revoke the consent and you must be able to remove the personal data if data subject requests deletion of their data.  When consent is the legal basis, use a consent to process personal data form, an example can be found here 

     Consent to use personal data 12.10.2022.docx (login required)

6. Draft a Privacy Notice

When you process personal data fill in and use ”Privacy Notice for Research Study” -document. Give or send Privacy Notice to participants. You also need ethical consent to participate, this is used when the legal basis is scientific research, a task in the public interest. When legal basis is consent, you need a consent to use personal data. 

The Privacy Notice is used to inform the research participants before you start to collect or otherwise process personal data. Information given e.g. in the privacy notice and research and Data Management Plan should not be conflicting. Privacy Notice is also needed as appendix for the ethical review.  Ethical review also requires a separate document Information to participants. This information should only contain practical information and personal data use should be explained in Privacy Notice, in any case there should not be conflicting information.  Remember to inform the research participants with a language they understand. Aalto-template covers the duty to 'document the processing activities' with record of processing activity according to GDPR. 

  • Send the privacy notice that you have given to data subjects also to [email protected]

7. If you disclose or transfer personal data to be processed outside of Aalto note the following:

  • If the other party processes personal data only for purposes, which are defined by Aalto, e.g. when you transfer personal data for a subcontractor or to cloud storage service, you must make a data protection agreement (DPA) with that party.
  • If you transfer personal data to another university or to a research institution, which together with Aalto defines the purposes for which personal data will be processed or Aalto and the other university have a joint personal data filing system, which can be used independently by both Aalto and the other university, both universities are considered to be controllers.
  • If you disclose personal data to another university or research institution, which can independently define the purposes for which personal data will be processed, you must agree in detail on e.g. the purpose for processing personal data and information of research participants before you disclose any personal data.
  • Personal data can be transferred outside of the EEA only under certain conditions. For more information, please see:

Aalto templates (login required):

The same person, who signs the main agreement, shall sign these agreements. Privacy agreements must be sent to: [email protected].

8. Inform data subjects about changes and update documentation

Personal data may only be processed for the purposes, which have been informed to the research participant prior to the beginning of the processing (by Privacy notice templates). If you need to process personal data for other purposes, you must inform the research participants on these new purposes and update all documents prior to the processing.

9. Anonymize data prior to archiving or publishing

The Finnish Social Science Data Archive  FSD is a certified research data repository serving researchers who wish to archive data. FSD offers advice on data management and management of personal data see : Other recommended data repositories are listed here:

-> Data publishing repositories

Anonymised data is no longer personal data. Anonymisation results from processing personal data in order to irreversibly prevent identification. In doing so, several elements should be taken into account by data controllers, having regard to all the means "likely reasonably” to be used for identification. See Working Party 29 Opinion 05/2014 on anonymisation techniques.

Before the anonymization, personal data has to be handled according to the above mentioned legislation, principles and guidelines.

If you wish to collect and reuse personal data that is not wholly anonymized, for example, interviews from professional experts on a certain field, contact the FSD repository staff to see if archiving could be achieved before you start collecting information, so that research participants can be informed in a manner required by the repository. The staff of the repository can help researchers with data curation and steps leading to a successful collection and preservation of research data. Use of pseudonymised data is still personal data and allowing only restricted access can be used as a measure to archive the data.

Education and training

Do you or your research community need training in data protection or data management? Get acquainted with university´s personnel training and webinars, and when necessary, ask for our legal and data management experts to discuss and train. 

Handling of Personal Data in Research - training materials:

Handling of Personal Data in Research 30.10.2023 (Aalto University, E. Glerean, A, Harju, E. Viitanen) - YouTubeSlides from the YouTube video aboveHow to draft a privacy notice 2.11.2023 (Aalto University, A. Harju, M. Rehbinder) - Youtube

RDM & Open Science Training

Training in Research Data Management and Open Science

We offer free and open to all training in research data management and open science.

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Training to support research in Workday Learning (external link)

You will find training to support research in Workday Learning -application.

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Trainings for IT and digital tools and information security on Workday Learning (external link)

You find trainings for IT and digital tools and information security on Workday Learning application.

Further information on handling personal data

In addition to this guidance, please orient yourself with Aalto Data Protection training in Workday and follow EU and national  guidance  A Preliminary Opinion on data protection and scientific research Scientific research and data protection - Data Protection Ombudsman’s Office ( The Steps of Handling Personal Data document provides an overview of the process.

Please contact your school’s data agent, lawyer or Aalto’s data protection officer if you need assistance.


Aalto University Data Protection Policy

The purpose of this data protection policy is to define the main principles, responsibilities and procedures that will be followed when personal data is processed at the university.


Data Protection, personal data (EU General Data Protection Regulation)

The EU General Data Protection Regulation (GDPR) is applied as of 25 May 2018 in all of the EU member states.

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Research and Innovation Services

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