Policy on the Processing of Personal Data of the LS AAI Service



This policy ensures that data collected as a result of the use of the LS AAI and Services is processed fairly and lawfully by Participants. Some of this data, for example that relating to user registration, monitoring and accounting contains “personal data” as defined by the European Union (EU) [GDPR]. The collection and processing of personal data is subject to restrictions aimed at protecting the privacy of individuals.



In addition to the definitions in the Terms of Use for Service Providers [ToU] document:

Personal Data - Any information relating to an identified or identifiable natural person [GDPR].

Processing (Processed) - Any operation or set of operations, including collection and storage, which is performed upon Personal Data [GDPR].

End User - An individual who by virtue of their membership of a recognised research community is authorized to use LS AAI services.



This policy covers Personal Data that is Processed as a prerequisite for or as a result of an End User’s use of LS AAI and Services. Examples of such Personal Data include registration information, credential identifiers and usage, accounting, security and monitoring records.

This policy does not cover Personal Data relating to third parties included in datasets provided by the End User or the research community to which they belong as part of their research activity. Examples of such data are medical datasets which may contain Personal Data.




  1. Declare that they have read, understood and will abide by the Principles of Personal Data Processing as set out below. 

  2. Declare their acknowledgement that failure to abide by these Principles may result in exclusion from the LS AAI, and that if such failure is thought to be the result of an unlawful act or results in unlawful information disclosure, they may be reported to the relevant legal authorities.



  1. The End User whose Personal Data is being Processed shall be treated fairly and in an open and transparent manner.

  2. Personal Data of End Users (hereinafter “Personal Data”) shall be Processed only for those administrative, operational, accounting, monitoring and security purposes that are necessary for the safe and reliable operation of LS AAI and Services, without prejudice to the End Users’ rights under the relevant laws.

  3. Processing of Personal Data shall be adequate, relevant and not excessive in relation to the purposes for which they are Processed.

  4. Personal Data shall be accurate and, where necessary, kept up to date. Where Personal Data are found to be inaccurate or incomplete, having regard to the purposes for which they are Processed, they shall be rectified or purged.

  5. Personal Data Processed for the purposes listed under paragraph II above shall not be kept for longer than the period defined in a relevant LS AAI or Service policy governing the type of Personal Data record being Processed (e.g. registration, monitoring or accounting) and by default shall be anonymised or purged after a period of 120 months.

  6. Appropriate technical and organisational measures shall be taken against unauthorised disclosure or Processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data. As a minimum, Participants shall:

    1. Restrict access to stored Personal Data under their control to appropriate authorised individuals;

    2. Transmit Personal Data by network or other means in a manner to prevent disclosure to unauthorised individuals;

    3. Not disclose Personal Data unless in accordance with these Principles of Personal Data Processing;

    4. Publish to the LS AAI a single contact point to which End Users or other Participants can report suspected breaches of this policy; 

    5. Respond to suspected breaches of this Policy promptly and effectively and take the appropriate action where a breach is found to have occurred;

    6. Perform periodic audits of compliance to this Policy and make available the results of such audits to other Participants upon their request.

    7. Ensure each Service interface provided for the End User must provide, in a visible and accessible way, a Privacy Policy containing the following elements:

      1. Name and contact details of the Data Controller Processing Personal Data; 

      2. Description of Personal Data being Processed; 

      3. Purpose or purposes of Processing of Personal Data;

      4. Explanation of the rights of the End User to:

        1. Obtain a copy of their Personal Data being stored by the Data Controller without undue delay; 

        2. Request that any Personal Data relating to them which is shown to be incomplete or inaccurate be rectified;

        3. Request that on compelling legitimate grounds Processing of their Personal Data should cease;

        4. Other rights compelled by the GDPR.

      5. The contact details of the Data Controller  to which the End User should direct requests in relation to their rights above;

      6. Retention period of the Personal Data Processed.

    8. Personal Data may only be transferred to or otherwise shared with individuals or organisations where the recipient:

      1. has agreed to be bound by this Policy and the set of common LS AAI policies, or 

      2. is part of a recognised Computer Incident Response Team framework and as part of an incident investigation to prevent active or suspected misuse of Infrastructure services, or 

      3. presents an appropriately enforced legal request.


Version 27 January 2022
Based on AARC Policy development kit (CC BY-NC-SA 4.0)

This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 654248 and from the European Union’s Horizon 2020 programme under grant agreement number 824087.