Personal data - questionnaires, interviews and observations

If you process personal data, e.g., if you collect or analyze personal data, use questionnaires, conduct interviews, or make observations of human participants in your study, you must ensure compliance with GDPR regulations. Informed consent and sufficient participant information are crucial aspects, which you can read more about below.

Please be aware that higher requirements for organizational and security measures apply when working with special categories of personal data (sensitive data). Read more about DTU’s GDPR regulations.

Research involving human participants for non-health scientific purposes in HEU applications

If you are applying for HEU and your research involves human participants for non-health scientific purposes, you must provide copies of ethics approvals only if legally required. Danish law mandates ethics approvals solely for research projects with health scientific purposes. However, obtaining informed consent from all participants is essential. For more information on informed consent, see below.

DTU advises obtaining a statement from the National Ethics Committee (NEC) or the Regional Ethics Committee (REC) confirming that ethical approval is not a legal requirement for your specific research project if there is any uncertainty about whether it falls under the Danish ethics committee system.

Data Protection Officer (DPO)

If you are applying for HEU, you are asked to state the name of DTU’s DPO in the application form. You must state the following information:

Birgitte Kofod Olsen, DPO,
DTU/Technical University of Denmark  
Anker Engelunds Vej 101, Building 101 A,
2800 Kgs. Lyngby

Mail: dpo@dtu.dk, Telephone: +45 45 25 25 25

Please read DTU’s Privacy Policy for further information regarding how DTU processes data as a data controller and DTU’s GDPR Inside pages.

Processing personal data and obtaining informed consent

For research involving the processing of personal data, obtaining informed consent from the individuals involved may be necessary.

Informed consent for projects with a health scientific purpose

Research projects with a health scientific purpose must be notified to the Danish ethics committees. To determine which ethics committee your research project must be notified to, please read on this DTU Inside page ‘Research Ethics’. In these cases, the responsible researcher must obtain informed consent from individuals whose personal data or biological material is being used in the project and ensure sufficient participant information. The information provided to these individuals must adhere to specific requirements outlined on the committees’ website. The committees have made available a range of consent forms that can be freely downloaded and adapted for use at DTU.

Do I need informed consent for all types of projects?

Even in cases where research projects do not require notification to ethics committees, it is important to consider whether consent is necessary for participation or the use of personal data (GDPR consent).

In most cases, regarding GDPR consent, informing individuals about the data's use might be sufficient and advisable without obtaining formal GDPR consent. The concept of "forskerhjemmel" or "legal basis for research" can often provide adequate grounds. For more information, please visit the GDPR DTU Inside pages. However, informed consent on ethical issues may still be necessary for certain research projects.

Import and export of material, including personal data

When importing and exporting material, including personal data, obtaining authorization from the EU for personal data transfer, including human biological material, is mandatory. The DTU GDPR Inside pages include an overview of relevant templates for this purpose. Please contact DTU’s GDPR team for further information regarding the record and transfer of personal data inside and outside the EU.

Additionally, securing a Material Transfer Agreement (MTA) is essential. Please contact your contract manager at the department. They will assist you. Contact Legal & Tech Transfer if further help is needed.

Danish regulations must be adhered to when conducting research projects in Denmark involving foreign partners, irrespective of potentially less stringent rules abroad. The determining factor is the project’s location within Danish territory.

DTU’s GDPR support channels and templates

DTU’s departments and central administration can assist you with questions related to GDPR. Please find an overview of GDPR roles and responsibilities.