AVG/GDPR: register of processing activities for research projects

Where and how to register processing activities?

For processing of personal data in the context of research projects, registration in the GDPR register is integrated in the policy on Research Data Management. Researchers have to register their processing activities in the online planning tool DMPonline.be. DMPonline.be contains a number of templates for drafting a Data Management Plan (DMP). DMP templates are essentially online forms with questions about various aspects of data management, and can also contain a series of GDPR questions. As a UGent researcher you can meet the required registration of processing activities by creating a DMP in the tool in which you complete these mandatory GDPR questions.

When creating a new DMP in the tool, you first have to indicate whether or not you will process personal data. If so, only the templates that contain the GDPR questions will be available to you (templates can be linked to UGent - or a subgroup within the university, e.g. a faculty - , or to external funders such as FWO, European Commission etc.)

There are two possible routes for documenting and registering processing activities in DMPonline.be:

  • If you want or have to prepare an extensive DMP for a research project, for example for an external funder, you can at the same time also register your processing activities by using a GDPR-compatible template (i.e. a DMP template where the GDPR questions are included because you indicate that you will process personal data in your research project)
  • If you are not writing an extensive DMP, but merely need to register processing activities with regard to personal data, you can use the specific UGent template 'GDPR record'. It only contains the GDPR questions and is available when you indicate that you (will) process personal data

The registration is only valid when all mandatory GDPR questions are completed.

Specific information for specific target groups:

  • For researchers with an FWO project that started from 1/01/2019, the GDPR questions have already been added to the DMP template of FWO in DMPonline.be so that registration takes place when this DMP is filled in.
  • Researchers who work with patient data (both retrospective and prospective research, both with patient data from UZ Gent and from outside) are legally obliged to submit an application for ethical approval to the Medical Ethics Committee. This application can only be submitted to the Medical Ethics Committee if the GDPR register is completed and added.

You will find a specific guide on how this registration should be done in this research tip. You will notice that each GDPR record/DMP with GDPR questions is also automatically shared with Hanne Elsen, UGent's Data Protection Officer. To register your processing activities, all you have to do is fill in all the GDPR questions in the online tool – at the moment you do not have to export and submit the GDPR record or DMP yourself to register your processing activity. If you are nevertheless asked to submit this GDPR record or DMP (e.g. by an ethics committee), the research tip will explain how you can export this document.

Which processing activities must be registered?

All researchers must register ongoing research projects, whether they started before or after 25/05/2018 in DMPonline.be. For new research projects the registration must be done at the start of the project (before the start of the actual data collection/processing). In addition, it is also important to update the GDPR questions during the project if necessary.

Further information and questions

For more information about the implications of the GDPR for your research and specific information about completing the GDPR register, three university-wide information sessions are organised:

  • Monday, April 29 from 10 am to 12 pm, Campus Dunant, classroom 1.2, Henri Dunantlaan 2, English
  • Tuesday, May 14 from 9 am to 11 am, Campus Aula, Academy Council Room, Volderstraat 9, Dutch
  • Tuesday, 14 May from 2 pm to 4 pm, Campus Aula academy council room, Campus Aula, Volderstraat 9, English

 

In addition, you will also find general information on how to correctly handle personal data on the RDM website.
For further questions about the new legislation and the GDPR register, please contact .