06.06.2019 23:23

Reuse of person names on specimen labels, in scholarly publications, and Data Protection (GDPR)

Data mobilization from specimen labels in natural history collections and liberation of materials citation from scholarly publications provide a new rapidly growing source of data ready to be analyzed and reused. Authority names, such as collectors or authors of new species receive a special interest, since this allows to document the contribution of a scientist to the field. David Shorthouse tool Bloodhound  is a typical representative of such a use, which is also in the sense of the DORA declaration on alternative research evaluation.

The General Data Protection Regulation of the European Community (GDPR) introduced in 2016, is applicable also to the use of personal data for scientific purposes. Does this fact mean that the use of person names included in specimen descriptions in taxonomic data collections, as for example personal names of collectors on specimen labels, is only allowed with the explicit consent of this person?

A look into the said regulation shows that this is not the case. Article 5 GDPR states explicitly that „processing (personal data) 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 purpose“. Personal data in specimen labels have necessarily been annotated with the consent of the concerned person, in many cases even by these persons themselves. Reuse of such data for archiving purposes or for scientific research purposes is therefore not restricted by the original purpose limitation; it is compatible with the initial purpose and therefore legitimate.

Further reading:

- The GDPR-compliance waltz: balancing necessity, legitimate interests and data-subject rights in the GBIF network