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Procedures regarding notification requirements to NSD

Procedures regarding notification requirements to NSD

This is a procedure description that will assist the head of department in fulfilling his/her research responsibilities regarding student and research projects subject to notification at his/her department.
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Responsibilities of the head of department

Reference is generally made to the document concerning the role and tasks of the research coordinator.

Access to NSD's Notification Archive

NSD has a notification archive (nsd.no, in Norwegian) of research projects that they have received notification about. Documents containing detailed information about the individual projects are archived here. It is therefore not necessary to archive documents associated with the project in Public 360.

The archive at NSD is has limited access. The dean, the head of department or the R&D adviser’s immediate manager must send an e-mail to NSD's contact at OsloMet, personvernombud@oslomet.no., with a access request.

The head of department and the R&D adviser (as well as the R&D advisor's immediate manager) should have access to the Notification Archive.

More about what the Notification Archive contains

  • Name of researcher/student, title, purpose, selection, type of information and storage, project period.
  • The legal basis for processing, applications and permissions.
  • Project overview with search function, so that you can easily find lists of projects you want to follow up.
  • Statistics page, including an overview of the number of notifications/years. This may provide an indication of whether the notification obligation is complied with.
  • Mailbox displaying projects with error messages.
  • The user overview shows which employees have access to the Notification Archive.
  • The billing page shows which projects NSD required payment for.
  • On the information page "About the Notification Archive" you will find useful advice on internal control and use of the Notification Archive.

Concretely regarding NSD

  • Ensure/check that new employees receive information about/are familiar with the guidelines and show where the information can be found.

  • Keep track of the project portfolio at the department, check whether the projects are subject to notification (has NSD been notified of all projects subject to notification?). To determine whether the project is subject to notification, try NSD’s notification test (nsd.no)

  • All projects must be linked to the department.
  • Verify that all projects have the necessary permits and that the requirements set in the permissions are followed up.
  • Check that researchers/students who are leaving OsloMet tie up the loose ends of active projects.
  • Make sure non-conformities are reported to the management and followed up.
  • Certify that there are procedures ensuring that student projects subject to notification are also reported.

Aid

  • Alternative ways to find out which researchers are processing personal information:

  1. Inquire about this in the application form for allocation of R&D time at the faculty, see examples of questions. By answering YES to one or more questions, the researcher can be followed up with guidance.

  2. Bring the question up during performance assessment interviews between the programme coordinator and researcher.
  3. Check accounts lists.
  4. Check whether the projects registered in Cristin coincide with the projects in NSD’s Notification Archive.
  5. Inquire with the head of research group.
  6. Be alert if you see a researcher with a lot of R&D time, but with few projects registered in NSD’s Notification Archive.

  • Information about privacy in research in the R&D handbook on OsloMet's website.

  • Refer to the central R&D administration and/or the head(s) of research group for guidance.

How

It is up to the head of department to decide how these tasks should be performed, including how and when informing.

Submitting notifications to NSD

Who performs the task? The project manager
Who gives guidance? The R&D administration and head of research group

Information for the project manager

  • How to submit the notification form? See the R&D handbook.

  • The head of research group and/or the R&D administration can assist the project manager regarding the contents of the notification form, depending on competence.

  • For student projects, the supervisor is the project manager and he/she is responsible for ensuring that the student is doing the right thing. The supervisor must have a copy of the letter/e-mail sent to the student.

Control and information

Responsible: the R&D administration

Information about serious non-conformities: notify sikkerhet@oslomet.no and the head of department with a few sentences and help clear up the non-conformity.

Provide input to the management and the responsible for the audit of the internal control system (personvernombud@oslomet.no) based on controls and non-conformity management.

When: Check the notification archive approximately twice a month.

When initiating new projects that process (sensitive) personal information, the following must be done:

  • Send a link to the R&D handbook, Scheduling, see Data collection /research ethical issues.

  • Send a link to information specifically aimed at the current project (special information). Check for example whether there are audio recordings and say something about what the project manager should pay particular attention to (e.g. do not use mobile phones for recording). When using audio recording as a method, send a link to the article about audio recordings  and put the data security coordinator in R&D, personvernombud@oslomet.no, on copy.

  • Projects that do not process audio recordings are forwarded to the data security coordinator in R&D, personvernombud@oslomet.no, who is then included in the case.

Review the notification form and other documents related to the project

  • Is the project manager still employed at OsloMet? If the project manager has quit and a new project manager has been appointed, a change request form (nsd.no) must be sent to NSD. If the responsibility for the project has been transferred to a new institution, this must be stated as well. A corresponding change request form must be sent when students quit before the expiration of the project period.

  • Is the project approved by NSD or is it still under review? If the project has not approved, consider whether the researcher needs help. Maybe all that is needed are small corrections that he/she can do himself/herself, or possibly in consultation with the head of research group or other researchers.

  • How is the data security in the processing of personal data? Look at what the notification form describes compared with the guidelines in the R&D handbook about Choosing online tools and storage sites for research data.. If the storage does not seem appropriate, send an e-mail to the project manager with a link to the said website and/or send an e-mail to the data security coordinator, personvernombud@oslomet.no, who is then included in the case.

  • Have other requests from NSD been answered /followed up? If the inquiry has not been answered/ followed up, is should be forwarded to the project manager. If it is difficult to answer the request from NSD at faculty level, please contact the data security coordinator in R&D for clarification.

  • Is the project completed? Clarify the status of the project. When the period stated in the notification form has expired NSD will contact the project manager by letter, which will be filed in both NSD's archive and in Public 360, to clarify the status of the project. The project manager must anonymise/ delete personal information in accordance with what stated in the notification form. If personal data is to be stored beyond the project period, this must be approved by NSD or a new consent must be obtained from the person registered, more information in the R&D handbook on Data processing after completion of project and long-term storage of data. 

  • Follow up and prevent non-conformities

Examples of questions in the application form for allocation of R&D time

  • Will personal data be registered in the research project?
  • Will sensitive personal information be registered?
  • Is the personal information anonymised so that it cannot be identified neither directly nor indirectly?
  • Have you notified NSD about the project?
  • Should the project apply for approval from other relevant bodies (e.g. REK)?
  • Have you conducted a risk assessment for safe storage of research data according to the college guidelines?
  • Do you need assistance in evaluating the right online tools for storing research data?