Preservation for research purposes
According to Section 35 of the PDA, a personal data file which is significant for purposes of scientific research or otherwise may be transferred for archiving to an institution of higher education or to a research institute or authority operating on a statutory basis. It is, however, required that the National Archives have granted permission for such archiving. The National Archives may grant corporations, foundations and institutions a permission to archive personal data files compiled in their own activities and fulfilling the requirements above. In the permission, the National Archives shall lay down rules for the protection of the files and for the monitoring of the use of personal data. Before granting such permission, the National Archives shall reserve the Data Protection Ombudsman an opportunity to issue an opinion on the matter.
Regarding data collected on the grounds of consent, the information provided to the data subjects should include how the data will be archived for secondary use (TENK: Ethical principles of research in the humanities and social and behavioural sciences and proposals for ethical review).
Regarding data collected without consent, further archiving seems compatible with the Act, as it is stated that personal data files should be either destroyed or transferred into an archive after the completion of a research project (cf. Section 14.1(4)).
Chapter 7 of the PDA concerns data security and storage of personal data. It states that the data controller must carry out the technical and organisational measures necessary for securing personal data against:
· Unauthorised access
· Accidental or unlawful destruction, manipulation, disclosure and transfer
· Other unlawful processing.
The following must be taken into account when carrying out the above mentioned measures:
· The techniques available
· Associated costs
· The quality, quantity and age of the data
· The significance of the processing to the protection of privacy
Data Protection Ombudsman: Duties [online]. Available at: <http://www.tietosuoja.fi/en/index/tietosuojavaltuutetuntoimisto/duties.h... [Accessed 10 September 2014].
National Advisory Board on Research Ethics, 2009. Ethical principles of research in the humanities and social and behavioural sciences and proposals for ethical review [pdf]. Available at: <http://www.tenk.fi/sites/tenk.fi/files/ethicalprinciples.pdf> [Accessed 9 September 2014].
The Personal Data Act, 1999 [pdf] Available at: <http://www.finlex.fi/fi/laki/kaannokset/1999/en19990523.pdf> [Accessed 10 September 2014].