Legal warning

Data protection policy


The GENDER STI Data Protection Policy aims to protect the personal data of those stakeholders related to the project. In general, GENDER STI involves data collection and processing of personnel data through questionnaires for surveys and interviews with stakeholders in order to gather information regarding the implementation of gender equality in STI bilateral and multilateral agreements.

The scope of our research covers EU Member States (MS) and Associated Countries (AC) on the one side, and selected third countries — Canada, the United States of America (US), Mexico, Brazil, Chile, Argentina, South Africa, India, South Korea and China — on the other side.


Data protection principles

The GENDER STI consortium is committed to processing data in accordance with the Horizon 2020 Ethical Principles for research and innovation activities. To this end, GENDER STI will comply with the existing ethical standards, such as the General Data Protection Regulation and international equivalents. Furthermore, each partner guarantees the protection of personal data, the rights of privacy and self-image in accordance with current legislation.


GDPR Compliance

Personal data are processed in full compliance with the General Data Protection Regulation (GDPR) and the present privacy policy pursuant to Article 13 of the GDPR. In particular, this process follows the definitions of personal data processing (Art. 4) and principles relating to processing of personal data (Art. 5).


GDPR Article 4 definitions

Personal data means information relating to an identified or identifiable natural person. 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 (Art. 2(a) GDPR).

Processing of personal data means any operation (or set of operations) performed on personal data, either manually or by automatic means, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.


GDPR Article 5 processing of personal data

Personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
  4. accurate and, where necessary, kept up to date; every reasonable step must 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 (‘accuracy’);
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’); and
  6. 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 (‘integrity and confidentiality’).


General provisions

This data protection policy applies to all personal data collected and processed by GENDER STI.

The Responsible Person shall take responsibility for the GENDER STI’s ongoing compliance with this policy.

Individuals have the right to access their personal data and any such requests made to GENDER STI shall be dealt with in a timely manner.


Lawful purposes

All data processed by GENDER STI must be done on one of the following lawful bases as defined in Article 6 of GDPR: consent, contract, legal obligation, vital interests, public task or legitimate interests. 

Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the GENDER STI’s systems. 


Data minimisation

GENDER STI shall ensure that the personal data we intend to process are adequate, relevant and limited to the sole purposes of the GENDER STI research project, in accordance with the data minimisation principle.



GENDER STI shall take reasonable steps to ensure personal data is accurate. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.


Archiving / removal

To ensure that personal data is kept for no longer than necessary, GENDER STI shall put in place an archiving policy for each area in which personal data is processed and review this process annually.



Surveys will be anonymised in order to ensure that the responses are not attributed to an identified or identifiable natural person.

To keep respondents’ identities private even after they answer all of the questions, we will build an anonymous survey by using Anonymous Responses in the survey hosting platform.


Use of data

The project will use previously collected data (‘secondary use’) that is publicly available and can be freely used for the purposes of the project.



GENDER STI shall adopt relevant technical and organisational measures in order to ensure that personal data is stored securely using appropriate software that is kept-up to date. 

Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

When personal data is deleted this should be done safely so that the data is irrecoverable. Appropriate back-up and disaster recovery solutions shall be in place.



In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, GENDER STI shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the public security authority.


Exchange of data and information shared WITH third countries

The GENDER STI  research and innovation action  focuses on how gender equality is taken into consideration at different levels of international cooperation dialogues in the area of STI between the EU Member States and Associated Countries and a selected set of 10 third countries, including Canada, the United States, Mexico, Brazil, Chile, Argentina, South Africa, India, South Korea and China. Thus, exchange of data and information sharing between EU and the third countries participating in GENDER STI is limited to collecting and transferring the information required to carry out the project’s activities. These include surveys and in-depth interviews with stakeholders, as well as design thinking workshops (Co-Design Labs) and project coordination activities.

Additionally, all GENDER STI research activities to be undertaken in the third countries involved in the project comply with the laws of the country in which the data is collected. At the same time, these activities are legal in all EU Member States.

In this regard, consortium members will gather and share information related to the project in order to implement the project activities, both in EU and the selected third countries, as well as to coordinate and manage the project as a whole. This information sharing will allow us to comply with the objectives of the project and ensure a smooth execution of the action.

Regarding personal data, it is worth mentioning that databases used for surveys are not shared and that the information collected is anonymized, in accordance with the project’s data protection policy described above.

Moreover, financial information from third countries eligible for funding under the Horizon 2020 framework (Argentina, Chile and South Africa) that will be sent to the coordinator is for restricted use by the Commission for the purpose of compliance with the Grant Agreement.

Therefore, apart from the information related to the project, there is not any material that will be imported from third countries to EU or exported from EU to third countries.