DiverSea – GDPR Compliance Checklist for Partners

ProjectDiverSea – Grant Agreement No. 101082004 (Horizon Europe)
Work packageWP7 – Ethics
To be completed byEvery DiverSea partner (one form per organisation)
Return toKemal Can Bizsel, can.bizsel@deu.edu.tr, WP7 lead / Murat Van Ardelan, murat.v.ardelan@ntnu.no
Deadline06/10/2026
Version1.0 – October 2026

1. How to fill in this checklist

  • Tick one box per question: YES, NO, or N/A (only if the question truly does not apply to your work).
  • Selecting “NO” as an answer does not indicate a failure. It just helps us see where support is needed. Please add a short note on what you plan to do and by when.
  • Use the comment column to give short evidence: a link, a document name, a server location, a retention period, etc.
  • Please ask your Data Protection Officer (DPO), if you have one, to check your answers before you sign.
  • If your organisation does not process any personal data in DiverSea, fill in Sections 2 and 3 then go directly to Section 14 and sign.
  • If you have been planning any action for the following items answered as “NO”, please provide brief information on what the planned action is and when it will be carried out by filling the table following the section 14.

    2. Partner details


    Located in EU/EEA? *

    Type of organisation *


    Person filling in this form



    Data Protection Officer (write “none” if not applicable)


    3. Screening

    If you answered NO to all three questions, go to Section 14.

    3.1 Does your organisation collect, store, use or share any personal data in DiverSea? (e.g. names, e-mails, affiliations, photos, videos, recordings, attendance lists, survey answers)

    3.2 Do you receive personal data from other DiverSea partners?

    3.3 Do you send personal data to other DiverSea partners or to people/organisations outside the consortium?

    4. What personal data you handle

    Activities

    4.1 Citizen science activities

    4.2 Workshops, forums, stakeholder meetings or events

    4.3 Surveys, interviews or questionnaires

    4.4 Online meetings that are recorded

    Types of data

    4.5 Names and contact details (e-mail, phone)

    4.6 Institution, school or employer

    4.7 Photos, video or audio recordings of people

    4.8 Location data linked to a person (e.g. GPS of citizen science observations)

    4.9 Special categories of data (health, ethnicity, religion, political opinion, genetic or biometric data)

    Participants

    4.10 Children or minors (under 18) take part

    4.11 People who may be vulnerable or unable to give informed consent take part

    4.12 Representatives of army, navy, coast guard or other security bodies take part (see also Section 12)

    Please write in the comment field in which country or countries these activities take place.

    5. Legal basis and informed consent

    5.1 We know and have written down the legal basis for each type of processing (usually consent).

    5.2 Participants get a clear information sheet before taking part (who we are, why we collect data, how long we keep it, their rights, contact person).

    5.3 The information sheet and consent form are in a language the participants understand.

    5.4 We collect written or electronic informed consent before collecting any personal data.

    5.5 Consent for photos, videos and recordings is asked separately and clearly.

    5.6 For children, we collect consent from a parent or legal guardian, and assent from the child.

    5.7 We keep the signed consent forms in a safe place and can show them if asked.

    5.8 Consent was in place before the first citizen science / stakeholder activity started. (If NO, give dates in the comment field.)

    6. Withdrawal and rights of participants

    6.1 Participants are told they can withdraw at any time, without giving a reason.

    6.2 We have a simple procedure for withdrawal (who to contact, how).

    6.3 When someone withdraws, we delete their personal data (or explain clearly why some data cannot be deleted, e.g. already anonymised).

    6.4 We have set a deadline for withdrawal of data (e.g. up to 2 weeks after data collection), and participants are told about it. (Write the deadline in the comment field.)

    6.5 We can answer requests from people who want to see, correct or delete their data.

    6.6 Participants have a named contact person for data questions.

    7. Collecting only what is needed

    7.1 We only collect personal data that is really needed for the DiverSea task.

    7.2 We use personal data only for the DiverSea purposes explained to participants.

    7.3 Where possible, we anonymise or pseudonymise data (remove or replace names) before analysis.

    7.4 We do not use personal data for profiling, tracking or systematic monitoring of individuals.

    8. Data security and encryption

    8.1 Files with personal data are encrypted when stored (e.g. encrypted drives, encrypted cloud storage). (Name the tool in the comment field.)

    8.2 Data is encrypted when sent (e.g. HTTPS, secure file transfer, no unprotected e-mail attachments).

    8.3 Access is protected by passwords and, where possible, two-factor authentication.

    8.4 Only named staff who need the data have access to it.

    8.5 Laptops, USB sticks and external drives with personal data are encrypted.

    8.6 Paper forms (e.g. signed consent forms) are kept in a locked place.

    8.7 Regular back-ups are made and stored securely.

    8.8 Personal data on the DiverSea project platform / dashboard is protected by access control.

    9. Where data is stored, and transfers outside the EU/EEA

    9.1 We know the physical location of all servers where we keep DiverSea personal data, including cloud storage. (Write the provider and country in the comment field.)

    9.2 All DiverSea personal data is stored on servers inside the EU/EEA.

    9.3 Personal data collected in a non-EU/EEA country (e.g. Ghana, Tanzania, Türkiye, Ukraine, UK) is transferred into the EU/EEA.

    9.4 Personal data is sent from the EU/EEA to a non-EU/EEA country.

    9.5 If data leaves the EU/EEA, a legal safeguard is in place (EU adequacy decision or Standard Contractual Clauses). (Name it in the comment field.)

    9.6 Data collected in a non-EU/EEA country also follows that country’s national data protection law.

    9.7 We did not send any personal data to UC San Diego while it was a DiverSea partner (relevant to Recommendation R1).

    10. How long data is kept, and deletion

    10.1 We have set a retention period for DiverSea personal data. (Write the period in the comment field, e.g. “until end of project + 5 years”.)

    10.2 The retention period is written down and told to participants.

    10.3 Personal data is deleted or anonymised when the retention period ends.

    10.4 We use a secure deletion method (not only moving files to the recycle bin).

    10.5 Contact lists for newsletters or events are kept separately and people can unsubscribe.

    11. Responsibility and oversight in your organisation

    11.1 Our organisation has a Data Protection Officer (DPO) or a named person responsible for data protection.

    11.2 The DPO (or responsible person) has been informed about our DiverSea activities and has checked them.

    11.3 Our DiverSea processing is listed in our organisation’s record of processing activities (GDPR Art. 30).

    11.4 We have checked whether a Data Protection Impact Assessment (DPIA) is needed and, if needed, done it.

    11.5 Our organisation has an ethics committee, or access to one, that can review DiverSea activities.

    11.6 We have a procedure for data breaches, including reporting to the authority within 72 hours when required.

    11.7 Staff working with DiverSea personal data have had basic GDPR / data protection training.

    11.8 We have data processing agreements with external service providers (e.g. cloud, survey tools, subcontractors) that handle personal data for us.

    11.9 We share personal data with other DiverSea partners only under agreed rules (e.g. Consortium Agreement, data sharing agreement).

    12. Civil use only

    12.1 Personal data and project data we collect are used for civil purposes only.

    12.2 No personal data is given to army, navy, coast guard or intelligence bodies, even if their representatives attend as observers.

    12.3 Observers from security bodies are informed that project data is for civil use only.

    Linked to Recommendation R12. If security bodies take part in your activities, please explain their role in the comment field.

    13. Personal data and AI tools

    13.1 We use AI or machine learning tools in DiverSea.

    13.2 Personal data (e.g. photos with people, names, citizen scientist records) is used as input to AI tools.

    13.3 If YES above: we have checked that the AI tool provider stores and handles this data in line with the GDPR.

    13.4 Faces and other identifying details are removed or blurred from images before AI processing, where possible.

    Wider AI questions (Explainable AI, risk assessment) are covered separately under Recommendation R9.

    14. Overall statement and signature

    14.1 Overall, our organisation handles DiverSea personal data in line with the GDPR (or, for non-EU/EEA partners, in line with GDPR-equivalent standards when handling data of EU/EEA residents).

    Actions planned for any NO answers

    Question no.

    What we will do

    By when

    Declaration





    Annex – Short explanations of terms

    Personal data

    Any information about a person who can be identified: name, e-mail, photo, voice recording, etc.

    Special categories of data

    Sensitive data such as health, ethnicity, religion, political views, genetic or biometric data. Extra rules apply.

    Anonymised / pseudonymised

    Anonymised: the person can no longer be identified. Pseudonymised: names are replaced by codes, but a key still exists.

    Encryption

    Scrambling data so only people with the key or password can read it.

    Retention period

    How long you keep the data before deleting or anonymising it.

    DPO

    Data Protection Officer – the person in your organisation who advises on data protection.

    Standard Contractual Clauses (SCCs)

    EU-approved contract terms used when personal data is sent outside the EU/EEA.

    Adequacy decision

    An EU decision that a non-EU country protects personal data to an EU-level standard (e.g. UK).

    DPIA

    Data Protection Impact Assessment – a risk check needed for higher-risk processing.

    Data processing agreement

    A contract with a service provider that handles personal data on your behalf.