Short presentation of the issues under discussion in Session 3 of the workshop "Data Protection Issues for Trusted Digital Repositories: Challenges and Solutions", during which the issues raised during the earlier sessions were revisited in terms of the implications for DRI as a trusted digital repository. During the workshop an oral response was given to questions raised in the final slides by a representative from the Irish Office of the Data Protection Commissioner. This was presented on the 16th of January, 2014 at the "Data Protection Issues for Trusted Digital Repositories: Challenges and Solutions" at the Royal Irish Academy.

1. Data repositories and data protection in
Ireland
Sinéad Redmond
Software Engineer
Digital Repository of Ireland
National University of Ireland Maynooth

2. What is the DRI?
• An interactive national trusted digital repository for
contemporary and historical, social and cultural data held
by Irish institutions.
• It provides a central internet access point and interactive
multimedia tools, for use by the public, students and
scholars.
• Four-year exchequer funded project, comprising six Irish
academic partners supported by the National Library of
Ireland, the National Archives of Ireland (NAI) and RTÉ
DRI Presentation

3. Review: three topics of today’s workshop
• Data protection issues for research participants
• Balancing ethical and legal standards
• Under what conditions do research data on individuals
constitute personal data?
DRI Presentation

4. Review: three topics of today’s workshop
Data protection issues for repositories
• Addressing different ethical standards and
expectations about audiences
• Changing European legal environment and
uncertainty about status of historical, statistical and
scientific research
• Under what circumstances might repositories be
unable to vindicate ethical commitments to research
participants, and how should they address this?
DRI Presentation

5. What does it mean to be a ‘trusted digital
repository’?
From our business requirements:
A Trusted Digital Repository
The system shall be a trusted digital repository.
1.1 It shall supply provide 'reliable, long-term access to managed digital
resources to its designated community, now and in the future'. (RLG-OCLC
Report).
1.2 It shall conform to the Data Seal of Approval guidelines or equivalent.
1.3 It shall be an access repository for the humanities and social sciences
(HSS).
1.4 It shall have disaster recovery process in place
DRI Presentation

6. Discussion points
• Is there a tension between data protection requirements and audit
requirements – email deletion?
• Is a user email address ‘personal data’?
• What information do we need to provide the user with on registration
about how we handle their data?
• At DRI, we will need to expose some user data to ‘Collection
Managers’ (archivists) in order to allow CMs to determine whether or
not to grant access to their collections. Is this a potential data
protection issue?
DRI Presentation

7. Discussion points
• Does the Data Protection Act apply to research data?
• Do we need to register annually as a data controller?
• Are we a data processor if we are ingesting, e.g., historical medical
records?
• If we need to register a data controller – can we do this as consortium
or do we need to register as single legal entity?
• Does providing ‘recommended’ links to users constitute direct
marketing?
DRI Presentation