How to proceed

If your dataset contains potentially sensitive data, please consult our Step-by-Step Guide on Data Publication for ETH Zurich Researchers. It contains information on the necessary steps to prepare your dataset for publication.

If your dataset contains health-related personal data, we additionally recommend consulting Scientific IT Services before publication.

Any disclosure risk must always be assessed at the level of the individual case. The ultimate responsibility for this lies with the researchers who submit a dataset for publication.

Which potentially sensitive data may be included in the Research Collection?

In addition, use the following table to check whether and under what conditions your dataset can be included in the Research Collection.

Due to legal, security and ethical requirements, the Research Collection is only suitable to a limited extent as a repository for publishing and archiving potentially sensitive data. The criteria in the following table must therefore be observed.

Data typeCan it be deposited in the Research Collection?Examples
Health-related personal data covered by the Human Research Act.

No, if not anonymized and/or no consent for publication resp. archiving is given.

No, provided it is information that directly identifies individuals (e.g. tables with keys used to de-identify a patient by coding / pseudonymization).

Yes, provided irreversible anonymization and consent of data subjects for publication resp. archiving has been obtained. Please however note the following caveats and general conditions:

  • In general, for sharing or archiving health-related data, we recommend using a repository specialized in the preservation of such data. The Research Collection can accommodate such data under the conditions stated here, but does not specialize in handling health-related personal data.
  • Due to the rapid progress of technical methods for de-anonymization, it is controversial whether clinical research data can be permanently and irreversibly anonymized at all. The Swiss Clinical Trial Organisation writes in its 2022 Guidance: [...] clinical research data should rarely, if ever, be treated and shared as anonymized data even after appropriate processing. Researchers should carefully weigh the benefits and risks and, if in doubt, should consider their data identifying" (p. 22). We recommend an appropriate risk assessment before publication.
  • Due to the risk of future de-anonymisation, which cannot be completely ruled out, we generally advise against granting Creative Commons licences for data publications that contain health-related personal data. This gives you greater scope to restrict the accessibility of the dataset at a later date, should your risk assessment change in the future.
  • For research projects that involve research with human subjects or the collection of personal data or the use of non-anonymized personal data, an application must be submitted to the ETH Zurich Ethics Committee.
  • Please refer to the factsheet Data Protection in Research Projects of the Legal Service of ETH Zurich.
  • Data about an identified or identifiable individual that relates to his or her health or disease
  • Genetic data

 

Ohter highly sensitive personal data

No

To determine whether your research data is highly sensitive personal data that must be classified as ‘strictly confidential’, you must perform a classification and risk assessment in accordance with the Directive "Inventarisierung und Klassifizierung von Informationen an der ETH Zürich" (Inventory and Classification of Information at ETH Zurich).

  • Personal data that, if improperly disclosed or processed, would have a serious impact on the health and economic situation of a person (life and limb).
  • Depending on the geographical and political context, statements about political or religious views, for example, must be classified as highly sensitive.
Personal research data that are not subject to the Human Research Act (cf. Art. 5 Data Protection Act) and have not been classified as highly sensitive (cf. above)

Yes, provided

  • that data has been classified as non-highly sensitive and non-health-related and
  • that the consent of the data subjects for publication resp. archiving has been obtained

 

Not classified as highly sensitive or health-related

  • completed questionnaires, transcripts or recording of interviews that can be directly attributed to individuals
  • photographs of identifiable persons
  • photographs of private spaces (e.g. houses, gardens) or objects (e.g. license plates of cars) that can be assigned to a person without much effort

Non-personal, strictly confidential research data

No

To determine whether your research data is strictly confidential, you must carry out a classification and risk assessment in accordance with the Directive "Inventarisierung und Klassifizierung von Informationen an der ETH Zürich" (Inventory and Classification of Information at ETH Zurich).

  • Unveröffentlichte Forschungsergebnisse, die bei vorzeitiger Offenlegung hohen oder sehr hohen Schaden anrichten können
  • Vertraglich als streng vertraulich vereinbarte Forschungsdaten (z.B. mit Kooperationspartnern, Dritten)
Unpublished research data subject to export controls

No

Information on classification can be found on the export control web pages.

  • Software or technologies for military goods
  • Software or technologies for dual use goods
Administrative documents

Usually no

Such documents are generally not intended for publication or sharing with other researchers, so a public repository is not the most appropriate tool for preservation. We recommend that such documents be archived in an appropriate internal repository of the research group or department.

Data documenting administrative processes related to a research project, e.g.

  • Contracts
  • Research plans
  • Accounting records
  • Invoices
  • Documents from personnel administration

Further information

Literature

Gahl, Brigitta; Haynes, Alan G; Sluka, Constantin; et al. (2022). Sharing of Data from Clinical Research Projects. Guidance from the SCTO’s CTU Network. Published by the Swiss Clinical Trial Organisation (SCTO). https://doi.org/10.54920/SCTO.2021.02

Krügel, Sybil (2019). The informed consent as legal and ethical basis of research data production. FORS Guide No. 05, Version 1.0. Lausanne: Swiss Centre of Expertise in the Social Sciences FORS. https://doi.org/10.24449/FG-2019-00005

Puebla, Iratxe; Lowenberg, Daniella; FORCE11 Research Data Publishing Ethics WG. (2021). Joint FORCE11 & COPE Research Data Publishing Ethics Working Group Recommendations. Zenodo. https://doi.org/10.5281/zenodo.5391293

Laws and guidelines

Directive "Informationssicherheit an der ETH Zürich" dated 17 December 2024 (German)

Directive "Inventarisierung und Klassifizierung von Informationen an der ETH Zürich" dated 1 January 2025 (German)

Factsheet Data Protection in Research Projects of December 2019, Legal Services of ETH Zurich

Federal Act on Data Protection (FADP) of 25 September 2020 (Status as of 1 September 2023) 

Federal Act on Research involving Human Beings (Human Research Act, HRA) of 30 September 2011 (Status as of 26 May 2021)

Ordinance on Human Research with the Exception of Clinical Trials (Human Research Ordinance, HRO) of 20 September 2013 (Status as of 26 May 2022)

Websites

ETH Zurich: Export Control

ETH Zurich: Research with Human Participants

ETH Zurich: Risk Management

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