Blad met gegevens, foto Vladislav Bulatov

Handling research data with care

Public datasets

Academic research often makes use of public datasets that do not contain easily traceable personal data.

These are distinguishable in:

  • Public datasets that can be downloaded, such as data from CBS or the European Social Survey and World Value Survey (WVS).
    These datasets do contain personal data, but they are anonymized or pseudonymized (whereby anonymized datasets do not contain personal data and are therefore not covered by this Directive). Theme policy Privacy & Protection of Personal Data - Scientific Research 11 Version 1.0 - May 2018 Tilburg University does not have the key to linking the datasets) and therefore (for Tilburg University) cannot be traced back to individuals. These datasets without traceable personal data therefore do not fall under the AVG. When using these datasets you often have to declare a number of things, such as that you are not using them commercially.
  • Public databases that can be used by means of a license.

Please note that if public datasets are combined, it is possible that personal data may be traceable (in the future).

Use of public datasets

When using public datasets, anonymized or pseudonymized personal data (without a link file) are in principle used which are thus not traceable. The researcher must ensure that the requirements in the license or when downloading are met and that the personal data is not traceable.

Note: If the public dataset, or any combination of datasets, contains personal data that is traceable, the research must meet all the requirements set forth in this policy. The data representative can assist in determining whether this is necessary.

Establishing lawfulness and purpose limitation

If personal data are processed in a scientific research, the so-called legitimacy and purpose limitation must first be established. After this, the so-called material requirements must be taken into account in order to ensure that personal data are handled with care.


  • Do we have a legal basis for processing?

Target binding

  • What do we want to do?

Material requirements

  • Do we handle personal data with care?

Processing basis public data

Processing basis in academic research is research in which a new dataset is set up in which research data is collected without obtaining it directly from respondents: justified interest. In this case, the research data are collected on the basis of information made public by the respondent herself.


Special personal data

According to the GDPR, special personal data may only be processed under strict conditions. In the case of academic research, the ban on processing special personal data may be lifted subject to certain conditions.

Obtaining permission for public datasets is impossible or requires a disproportionate amount of effort:

  • Informing the public by means of a privacy statement

Target binding

The second requirement is that there must be purpose limitation: there must be a well-defined, clearly defined purpose.