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ICTs, data and vulnerable people: a guide for citizens

Authors:
  • The European Commission Joint Research Centre

Abstract

ICTs, personal data, digital rights, the GDPR, data privacy, online security… these terms, and the concepts behind them, are increasingly common in our lives. Some of us may be familiar with them, but others are less aware of the growing role of ICTs and data in our lives - and the potential risks this creates. These risks are even more pronounced for vulnerable groups in society. People can be vulnerable in different, often overlapping, ways, which place them at a disadvantage to the majority of citizens; Table 3 in this guide presents some of the many forms and causes of vulnerability. As a result, vulnerable people need greater support to navigate the digital world, and to ensure that they are able to exercise their rights. This guide explains where such support can be found, and also answers the following questions: - What are the main ethical and legal issues around ICTs for vulnerable citizens? - Who is vulnerable in Europe? - How do issues around ICTs affect vulnerable people in particular? This guide is a resource for members of vulnerable groups, people who work with vulnerable groups, and citizens more broadly. It is also useful for data controllers1 who collect data about vulnerable citizens. While focused on citizens in Europe, it may be of interest to people in other parts of the world. It forms part of the Citizens’ Information Pack produced by the PANELFIT project, and is available in English, French, German, Italian and Spanish. You are welcome to translate this guide into other languages. Please send us a link to online versions in other languages, so that we can add them to the project website.
ICTs, data and
vulnerable people:
a guide for citizens
This project received funding from the European Union’s
Horizon 2020 research and innovation programme under
grant agreement No 788039. This document reects only
the author’s view and the Agency is not responsible for any
use that may be made of the information it contains.
Disclaimer
Citation
Contact
PANELFIT consortium (2021) ICTs, data and vulnerable people: a guide for citizens.
UPV-EHU, Bilbao.
For more information about the PANELFIT project, please contact:
Aliuska Duardo
UPV/EHU, GI.Derecho y Genoma Humano/Law and the Human Genome R.G
Edicio de Biblioteca, Local 6A7
48940 Leioa
Biscay, Spain
aliuska.duardo@ehu.eus
+34 94 601 7105
www.panelt.eu
panelt
Panelt.news
2
ICTs, data and vulnerable people: a guide for citizens
Contents
About this guide
Glossary of key terms
What are the ethical and legal issues around ICTs?
What is vulnerability?
Vulnerable groups in Europe
How do the ethical and legal issues around ICTs affect vulnerable people?
What can you do?
Useful resources
Further reading
Further watching and listening
Acknowledgements
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ICTs, data and vulnerable people: a guide for citizens
About this guide
ICTs, personal data, digital rights, the GDPR, data privacy, online security… these terms, and
the concepts behind them, are increasingly common in our lives. Some of us may be familiar
with them, but others are less aware of the growing role of ICTs and data in our lives - and
the potential risks this creates.
These risks are even more pronounced for vulnerable groups in society. People can be vul-
nerable in different, often overlapping, ways, which place them at a disadvantage to the
majority of citizens; Table 3 in this guide presents some of the many forms and causes of
vulnerability. As a result, vulnerable people need greater support to navigate the digital
world, and to ensure that they are able to exercise their rights. This guide explains where
such support can be found, and also answers the following questions:
What are the main ethical and legal issues around ICTs for vulnerable citizens?
Who is vulnerable in Europe?
How do issues around ICTs affect vulnerable people in particular?
This guide is a resource for members of vulnerable groups, people who work with vulne-
rable groups, and citizens more broadly. It is also useful for data controllers1 who collect
data about vulnerable citizens. While focused on citizens in Europe, it may be of interest to
people in other parts of the world.
It forms part of the Citizens’ Information Pack produced by the PANELFIT project, and is
available in English, French, German, Italian and Spanish. You are welcome to translate this
guide into other languages. Please send us a link to online versions in other languages, so
that we can add them to the project website.
1. The PANELFIT guide to responsible research and innovation provides more information for data controllers.
4
ICTs, data and vulnerable people: a guide for citizens
Glossary of key terms
Table 1 explains some of the key terms used in this guide. These are not the ‘nal word’ on
these terms, but provide a useful denition for those new to the terminology around ICTs,
data and vulnerable groups.
5
ARTIFICIAL INTELLIGENCE AI refers to software applications that, given a specic goal, can
learn, reason and make decisions. AI technologies have many diffe-
rent applications, such as smartphone assistants, translation tools,
self-driving cars and facial recognition.
CYBERSECURITY This refers to how well protected private online data and informa-
tion are; for example, how safe they are from being hacked, stolen
or made public without permission.
DATA COMMERCIALISATION This means processing data about individuals or groups in order to
make money; for example, through targeted online advertising or
by selling data to others.
DATA CONTROLLER A data controller is anyone who obtains data, including perso-
nal data, to use for a specic purpose. It can be a company, an
organisation, a government or local authority, a public body (e.g., a
school or hospital) or a research institute, among others.
DATA MANAGEMENT Data management covers the whole life cycle of data processing:
collection, use, storage, sharing and deletion. It also refers to the
fact that whoever collects your data (the data controller) must con-
trol what they are used for, and who can use them.
DATA PROTECTION Nothing should happen to your personal data unless you have
given your permission for this. Data controllers are required, under
EU law, to put in place measures to ensure it is stored securely and
privately. Your data should not be shared, or made publicly avai-
lable, unless you have agreed to this.
DATA SUBJECT The person whose personal data is being collected and used by
the data controller.
ICTs, data and vulnerable people: a guide for citizens
Table 1. Key terms for understanding ICTs, data and vulnerable groups
DATA USE AND REUSE When asking for your data, data controllers should explain the pur-
poses for which it will be used (e.g., a census, a research project). If
they, or a third party, want to use your data for a further purpose -
known as data reuse - they should ask again for your consent to do
so. They cannot assume you are happy for your data to be reused.
DIGITAL DIVIDE This describes the gap between people who are able to benet
from technology (e.g. ICTs, the internet) and those who cannot.
This phenomena is becoming increasingly important as more and
more aspects of our lives move partly or fully online (e.g. edu-
cation, healthcare, banking, shopping). Those with limited or no
access to digital services risk being ‘left behind’.
DIGITAL LITERACY Sometimes referred to as ‘ICT literacy’, this refers to a person’s
ability to nd, evaluate and communicate information on digital
platforms and devices.
DIGITAL RIGHTS Digital rights are human rights in the digital environment, or hu-
man rights that are enabled through technology and the internet.
These include, among others, the right to privacy and the right to
withdraw consent for data use.
DISCRIMINATION Discrimination means making unjustied distinctions between
people based on perceptions about that group, or the category (or
categories) they belong to; for example, their race, gender, age,
religion or sexual orientation, among others.
GDPR The General Data Protection Regulation oversees how European
citizens’ personal data is managed. In effect, it sets out the laws
that protect your personal data and keep them private.
ICTS Information and communication technologies include all forms of
technology used for communication, such as the internet, mobile
phones and smartphones, computers, social media networks,
video-conferencing tools, and many others.
INFORMED CONSENT With respect to data and ICTs, this refers to asking the data subject
for permission to use their personal data in a specic way - which
must be done before collecting or using their data. Informed con-
sent is not always needed, as it is just one of the criteria for lawful
data processing under the GDPR.
PERSONAL DATA Personal data is anything that relates to you as an individual: your
name, age or address, for example. In the digital world, it can also
include your interests, habits and preferences; for example, pages
you ‘like’ on social media, websites you visit to buy items, and
YouTube videos you have watched, among many others.
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ICTs, data and vulnerable people: a guide for citizens
PRIVACY In relation to ICTs and data, privacy refers to how secure your
information is (data protection) and how widely you want it to be
shared (e.g., publicly, or only by the data controller).
STIGMATISATION Stigmatisation, or social stigma, means disapproving of, or discri-
minating against, a person or group of people based on percep-
tions about the person or the group(s) to which they belong.
VULNERABLE PEOPLE Vulnerable people are those who, for any number of reasons, nd
themselves at a disadvantage when compared to the majority of
people in society. You can nd examples of vulnerable groups later
in this guide (Table 3). People in certain social groups are someti-
mes referred to as ‘disadvantaged’ or ‘socially excluded’.
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ICTs, data and vulnerable people: a guide for citizens
Source of digital rights denition: www.apc.org/en/news/coconet-what-are-digital-rights
What are the ethical and
legal issues around ICTs?
ICTs have brought many benets to our lives. They have made it possible to speak quickly
and cheaply to people across the world; they have given us instant access to more informa-
tion than we ever knew we needed; they have brought huge advances in healthcare; they
have helped us to combat poverty and bring education to more and more people globally.
Yet these advancements have not been without costs. Many ICTs require data to function
and, as a result, companies, organisations, researchers and governments are increasingly
asking for – or simply taking – our data. Data and information are powerful, and those who
control them are increasingly able to nd out about every aspect of our lives, both profes-
sional and private – and then benet from this information, whether nancially, politically or
in other ways.
For many people, debates around these ethical and legal issues are difcult to understand,
or dismissed as boring or irrelevant to their everyday lives. Furthermore, the ethical debates
around ICTs evolve very quickly, and it can be hard for people to keep up with them. As a
result, we are often quick to give up our rights in return for the many benets that ICTs bring.
But as ICTs continue to spread into every aspect of our lives, growing demands for our per-
sonal data make these issues increasingly important. Who is getting hold of our data? Who
else are they sharing it with? What are they doing with it – and what can I do to control this?
ICTs are a rapidly developing eld, and as such, the ethical and legal issues around them are
also constantly changing. Table 2 highlights some of the current ethical and legal issues for
citizens around ICTs.
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ICTs, data and vulnerable people: a guide for citizens
Table 2. Ethical and legal issues related to ICTs
MANY CITIZENS HAVE A LIMITED UNDERSTANDING OF,
AND/OR INTEREST IN, ISSUES AROUND ICTS
Issues around ICTs are often difcult for non-experts to
understand. This is true for both legal issues (e.g., the details of
online terms and conditions) and ethical issues, such as surveil-
lance and the future role of Articial Intelligence. For many, this
is combined with a lack of interest in what are often complex
subjects, or documents full of legal terminology (e.g., the
GDPR). In other instances, citizens may want to know more, but
not know where to nd help with understanding these issues.
This has knock-on effects, such as people clicking ‘I agree’
without having read, or having not understood, a website’s
terms and conditions or privacy policy. Furthermore, people
may not know about the laws in place to protect their rights in
the digital world – which makes it harder for them to exercise
these rights.
THERE ARE A NUMBER OF BARRIERS THAT LIMIT CITIZENS’
UNDERSTANDING
For many people, there are major barriers that deny them
access to further information about ICTs and digital rights.
Language is one: much of this information is in English and
other major European languages, but not everyone in Europe
is uent in these languages.
Furthermore, much of this information is only available online.
For ofine communities – those with limited or no access to the
internet – it remains out of reach. This lack of access to informa-
tion accessed via ICTs is an example of the ‘digital divide’.
THERE IS A PERCEIVED IMBALANCE OF POWER BETWEEN
CITIZENS AND TECHNOLOGY COMPANIES
The ‘tech giants’ – large global technology companies, such as
Facebook and Google – can seem very powerful. For some
people, this can also be true for smaller technology compa-
nies. As a result, it can be difcult to say ‘no’ or ‘I don’t agree’
when companies ask for our data.
People think they may miss out on the benets from using their
services, or feel that these companies will simply have access
to their data anyway. This sense of powerlessness is increased
when people cannot or do not read about their digital rights.
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ICTs, data and vulnerable people: a guide for citizens
THE DIVERSITY AMONG CITIZENS MEANS PEOPLE HAVE
DIFFERENT CONCERNS AROUND ICTS
Different groups in society use ICTs in very different ways – and
therefore have varying concerns, problems and challenges
with using ICTs. Providing the information each group or
individual needs, and in the format and language they want, is
challenging.
As a result, a lot of information about ICTs and digital rights is
generic – which makes it harder for people to nd what they
need.
THE ICT LANDSCAPE IS CONSTANTLY CHANGING
ICTs and digital rights are complex. Adding to this complexity
is the fact that technology is always developing, and our data
are being used in new and increasingly complicated ways.
This brings its own challenges, not least the fact that there are
always new laws, procedures and developments for us to try to
understand.
This complexity is increased due to the different interpretations
of these rights, and the protections put in place to ensure them
(e.g., the GDPR) in different countries.
Source: Adapted from the report of the COST Action/PANELFIT workshop held in March 2020; supplemented by the other resources listed at
the end of this guide.
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ICTs, data and vulnerable people: a guide for citizens
11
What is vulnerability?
The ethical and legal challenges around ICTs affect everyone, in Europe and beyond. For
vulnerable people and groups in society, however, these risks are often even more acute –
and in many cases, their ability to adapt to these risks is lower. Furthermore, there is a possi-
bility that some vulnerable people will miss out on the opportunities and benets that ICTs
can bring if they are unaware of them, or if their fear of these risks outweighs their desire for
the benets.
But who counts as vulnerable? This is not a simple question to answer because, for a number
of reasons, vulnerability is complex. Box 1 provides a summary of this complexity, and the
factors that contribute are then explained in more detail.
Box 1. How to ‘unpack’ vulnerability
Vulnerability is complex. The factors outlined in this guide do not cover all the ele-
ments of vulnerability, but highlight that it is complicated. The overall message is that
vulnerability is a uid, dynamic concept, and most people do not t into neat, binary
categories of vulnerability.
Instead, we suggest seeing vulnerability as a spectrum: individuals or groups can have
high or low levels of vulnerability, which can be xed (static) or changing (dynamic).
Vulnerability is likely to change over a person’s lifetime: with age, through changing
personal circumstances, and due to factors beyond their control.
It is worth noting that everyone is potentially vulnerable, and that their resilience – their
ability to cope with vulnerability – is determined by their access to resources (e.g.,
public services available in a country) and cultural factors (e.g., their support networks).
Above all, it is important to remember that members of the vulnerable groups descri-
bed in this guide are people rst and foremost. Any other denition – as a data subject,
a vulnerable person, even as a citizen – should be secondary to this.
ICTs, data and vulnerable people: a guide for citizens
People can be vulnerable in many different ways. For example, vulnerability can be caused by nancial problems
(e.g., unemployment, unmanageable debts) or health- and capacity-related barriers, such as illness, old age or
disability. Other causes of vulnerability can be location-based, such as living in remote rural areas with few fa-
cilities (e.g., hospitals, schools). The causes of vulnerability can be societal, such as prejudice against refugees,
foreigners or Travellers. They can also be due to discrimination based on (among others) race, ethnicity, nationa-
lity, class, caste, religion, belief, sex, gender, language, sexual orientation, gender identity and sex characteristics.
The form that a person’s vulnerability takes can be complicated. At an individual level, a person may be affected
by poor health and low nancial capacity. These vulnerabilities have different impacts, but are often intercon-
nected; indeed, one cause of vulnerability can often exacerbate others, creating a ‘vicious cycle’. Building on the
example given, a lack of money can lead to ill health (e.g., due to a limited diet or unsanitary living conditions)
and the resulting ill health can make it harder to nd a job – which in turn increases or maintains the person’s
nancial vulnerability.
Individuals within a vulnerable group may experience different impacts, and levels of impact, from a shared
situation. For example, some refugees in Europe may be more vulnerable than others due to a range of factors.
These may include: the country they are from (e.g., why they left and whether this caused trauma or psychologi-
THE CAUSES OF VULNERABILITY VARY GREATLY
PEOPLE OR GROUPS MAY EXPERIENCE MORE THAN ONE FORM OF VULNERABILITY
VULNERABILITY CAN VARY WITHIN A GROUP IN SOCIETY
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ICTs, data and vulnerable people: a guide for citizens
cal issues); the country in which they are currently living (e.g., its facilities for refugees, public attitudes towards
refugees); and their education, training and competencies (e.g., language skills, professional qualications).
These factors inuence their ability to settle, nd work and access the facilities available. So while it is true to say
‘refugees are vulnerable’, the severity of that vulnerability, and people’s experience of it, will vary greatly within
that broad group. Indeed, describing a certain type of vulnerability with one broad term may overlook indivi-
duals’ specic challenges, which makes it harder to address them.
While some vulnerabilities do not change signicantly during a person’s lifetime (e.g., incurable disabilities),
others can worsen or improve over time. For example, many people experience changing personal circumstan-
ces, such as in their nancial status or health. External factors that affect their vulnerability may also change; this
could be the political climate in their country, which may bring in a government that is less supportive of margi-
nalised groups. In other cases, the cause of a vulnerability may become redundant over time, such as a health
issue improving, or unemployed people nding work, which removes or reduces their nancial vulnerability.
Some of these changes are predictable, such as increasing vulnerability with age. In some instances, though, the
cause of vulnerability can be rapid and unexpected: people may be hit by phenomena beyond their control,
such as extreme climate events. These ‘shocks’ can create a vulnerability for which people have not prepared.
When considering vulnerability within society, there is often a temptation to assume characteristics for certain
groups – but they may not apply to all members of that group. For example, refugees may be well educated and
speak the native language of their host country well. However, they are still likely to share certain traits with other
refugees, such as more limited access to resources and employment opportunities (compared with non-refuge-
es), or abuse, neglect, exploitation, prejudice and antagonism from others in society.
VULNERABILITY CAN BE DYNAMIC
VULNERABILITY CAN BE ASSUMED
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ICTs, data and vulnerable people: a guide for citizens August 2021ICTs, data and vulnerable people: a guide for citizens
Vulnerability is also subjective. One person may feel vulnerable, or class themselves as such, whereas someone
else in a similar (or perhaps even worse) situation may not. At the same time, any citizen might see themselves
as vulnerable, for reasons that are not immediately evident to others.
Certain groups that are often regarded as vulnerable need careful denition, and at times even sub-categori-
sation. For example, children and young people (those aged 16-25) are often identied as vulnerable, but the
nature of vulnerability will vary widely, depending on whether they are:
school students, who are not legally able to make all decisions for themselves
in higher education, which may lead to stress or other mental health issues
in employment, which is often low paid or insecure among this age group
outside of education and employment, which can lead to a number of vulnerabilities (e.g., nancial,
poor living conditions, mental health issues).
In some instances, it is not (just) the individuals within a group who are vulnerable. Certain groups may nd their
cultural heritage is under threat, or their access to it is. This could be due to external threats, such as climate
change: in polar regions, indigenous peoples’ entire way of life is under threat. People’s cultural resources can
also be vulnerable, such as their language, their family and social structures and networks, and their natural
heritage and environment.
BREAKING DOWN CERTAIN TYPES OF VULNERABILITY
VULNERABILITY CAN AFFECT THE PERSON – BUT ALSO THEIR CULTURE
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ICTs, data and vulnerable people: a guide for citizens
Vulnerable groups in Europe
While keeping this complexity in mind, there is often a need to identify vulnerable groups
and individuals (e.g., to determine who is eligible for support). So who can – or should – be
seen as vulnerable in Europe? The EU2 has dened vulnerable persons as:
“Minors, unaccompanied minors, disabled people, elderly people, pregnant women,
single parents with minor children, victims of trafcking in human beings, persons
with serious illnesses, persons with mental disorders and persons who have been
subjected to torture, rape or other serious forms of psychological, physical or sexual
violence, such as victims of female genital mutilation.
Expanding on this denition, Table 3 identies several vulnerable groups within Europe,3
as well as people experiencing certain types of vulnerability.4 This should not be seen as a
complete list of vulnerable groups in Europe; given the changing nature of vulnerability, this
would be impossible to achieve. However, it offers a useful starting point for thinking about
who is vulnerable.
Table 3 also provides an example for each group of how their vulnerability may affect them
in terms of ICTs (see the next section for more discussion on this subject). The examples
given are to illustrate possible types of ICT-related vulnerability for each group; many other
types are likely to exist, depending on the degree of vulnerability and other circumstances.
We have not attempted to sort these groups under broader headings or themes. To do so
would contradict one of our key recommendations: that vulnerability is seen as dynamic
and complex, not a ‘label’ applied to certain groups or individuals. Labelling large groups in
society as vulnerable can increase the discrimination and stigmatisation they face.
15
ICTs, data and vulnerable people: a guide for citizens
2. Art. 21 of Directive 2013/33/EU (Recast Reception Conditions Directive).
See: https://ec.europa.eu/home-affairs/what-we-do/networks/european_migration_network/glossary_search/vulnerable-person_en
3. While this guide focuses on Europe, many of the types of vulnerability are experienced elsewhere. At the same time, there are further causes
and types of vulnerability found outside of Europe.
4. For example, ‘refugees’ are a vulnerable group, but ‘being poor’ and ‘being homeless’ are people experiencing vulnerability; it is a description
of their situation at a given time and in a given context.
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ICTs, data and vulnerable people: a guide for citizens
How do the ethical and
legal issues around ICTs
affect vulnerable people?
The ethical and legal issues around ICTs – such as those related to data privacy, data com-
mercialisation, and the growing use of new technologies (e.g., facial recognition) affect
everyone in society. But vulnerable people and groups in society are often at a greater risk
of harm than others – and at risk in different ways. Box 2 presents some of these.
Box 2. How do ICTs affect vulnerable people in particular?
Vulnerable people and groups face additional risks of having their data used
in ways they may not want or agree to (e.g., refugees who are under greater
state surveillance). While this is an issue for all citizens, vulnerable people may
nd it harder to prevent this: for example, they may be incapable of granting
consent, or may not be uent in the national language(s) of the country they
live in.
Power imbalances between data subjects and data controllers may be exacer-
bated for vulnerable data subjects. For example, in cases where personal data
is open to misuse by data controllers, vulnerable people may nd they are less
able to control or prevent this, because they have less power, knowledge or
awareness of the issue.
There is a risk of (greater) stigmatisation as people are put into groups or cate-
gories (e.g., elderly, immigrant) for the purposes of research and analysis.
These risks do not just relate to the nature of a person’s vulnerability, but also the kind of
personal data that is being collected and used. Certain types of data – such as information
about a person’s religion, medical history or sexual orientation may bring a greater risk,
depending on the place and context in which they are used.
Furthermore, as mentioned, vulnerability can change over time. This raises issues in terms of
personal data. Individuals or groups who are not vulnerable when they share their data may
become so later on. As a result, the conditions under which they gave their consent for their
data to be used may no longer apply. Research teams that are under-resourced may lack the
time, money and, in some cases, information they need to implement measures to ensure
the data and privacy rights of their subjects are enforced.
Once again, the message is this: vulnerability is complex! Table 3 highlights how different
vulnerable groups in society may be affected in relation to the ethical and legal issues around
ICTs and data. We are not saying these examples apply to everyone in these groups; they
are simply meant to illustrate the ways in which vulnerability, and vulnerability related to ICTs
and data, can occur.
Table 3. Examples of vulnerable groups in Europe, and the nature of their vulnerabilities
Vulnerable group Possible vulnerability Possible vulnerability with
respect to ICTs and data
Women Pregnant or breastfeeding
women may be, or may feel,
more vulnerable than other
women; for example, due to
changes in their health.
Women who have undergone
gender reassignment surgery
may have data stored about them
that no longer reects their status.
Single parents or guardians;
parents or guardians of vulne-
rable children or dependants
Additional care duties may leave
them with less time and resour-
ces to take care of themselves,
increasing their vulnerability.
They may have less time to read
about and understand ICT-related
issues.
Homeless people People in this situation often
experience greater health risks
and an increased risk of violence,
unemployment and poverty.
They are likely to have lower
access to information about these
issues than others in society.
Also, data about them may be
collected without their informed
consent (e.g., when they use
homeless services provided by
charities).
17
ICTs, data and vulnerable people: a guide for citizens
People with addiction(s), such
as drug addiction and/or
alcoholism
People living with addiction face
many forms of vulnerability, such
as health risks, an increased risk
of violence, unemployment and
poverty.
They may have reduced capacity
to understand information about
their ICT and data rights.
People suffering from, or at
risk of, domestic violence, and
psychological and/or sexual
abuse
People facing violence and
abuse are likely to experience
a range of vulnerabilities, such
as physical and mental health
issues.
In some situations, victims’ access
to information may be restricted
as part of the abuse they suffer;
for example, they may live with
a partner who restricts what they
can do or where they can go.
People who have been
subjected to torture, rape or
other forms of psychological,
physical or sexual violence,
such as victims of female
genital mutilation
Among many other forms of
vulnerability, people who have
experienced these issues are
likely to face long-term trauma
or other psychological damage,
in addition to the impacts on
their physical health.
A reluctance to share their perso-
nal data – for example, if they are
a migrant or lack legal status in a
country – may mean that victims
are less willing to seek medical
help or inform the police of their
situation.
Victims of human trafcking A lack of legal status in a country
may mean these people do not
access the support available; for
example, they may fear being
deported.
These people may be unable to
access online services or informa-
tion, depending on the conditions
they nd themselves in (e.g.,
illegal connement, modern-day
slavery). At the same time, by not
being ‘in the system’, they may be
overlooked by service providers
who could help them.
Religious minorities It can be difcult to erase societal
bias away from these groups.
Some people consider their
religion to be a private matter,
but certain data-collection
processes still ask people to state
their religion (e.g., tax regula-
tions in Germany).
LGBTQIA+ people5 and sexual
minorities
Individuals in this group still
face widespread discrimination
across Europe.
New technology that violates pri-
vacy (e.g., facial proling) may be
more likely to target such groups.
5. This stands for lesbian, gay, bisexual, transgender, queer, intersex and asexual.
18
ICTs, data and vulnerable people: a guide for citizens
Transgender populations Individuals in this group still face
widespread discrimination across
Europe. For example, Hungary
recently passed a law ending the
legal recognition of trans status.6
Male/female tick boxes, which
are commonly found on many
data-collection forms, discriminate
against them, while the ‘traditional’
language used in many online
situations (e.g., he/she, his/her)
does likewise.
Prisoners Prisoners are cut off from their
support networks, and often face
additional threats, such as a
greater risk of violence in prison.
Being in prison may reduce their
access to information about their
data and digital rights.
People leaving prison Newly released prisoners may
lack support networks and nd
it hard to gain employment or
secure housing.
Their vulnerable state may reduce
access to information about their
data and digital rights. Depending
on how long they were in prison,
they may be unaware of develop-
ments in terms of data protection
and privacy.
People who are under-educa-
ted or poorly educated
Their vulnerability is exacerbated
by not being aware of, or unable
to understand, support systems
to reduce their vulnerabilities.
They tend to have lower incomes,
increasing their nancial vulne-
rability.
Information about ICTs and data
rights tends to be complex and
hard to understand; low education
will increase this barrier.
People who are outside of
training and/or education
This situation can exacerbate
many types of vulnerability,
including nancial, health (espe-
cially mental health) and support
networks.
Information about ICTs and digital
rights is often passed through
formal settings, such as schools or
colleges. Being outside of these
reduces people’s access to such
information.
People who are misinformed,
including those who may not
be able to understand the
information provided
Information is power; those who
cannot access or understand the
information designed to help
them are, as a consequence,
more vulnerable than those who
can.
This is true of digital information as
well as non-digital forms.
6. See: www.theguardian.com/world/2020/may/19/hungary-votes-to-end-legal-recognition-of-trans-people
19
ICTs, data and vulnerable people: a guide for citizens
People with learning
difculties, such as dyslexia,
dysorthography, dysgraphia
and dyscalculia
Learning difculties can make
people vulnerable in multiple
ways. For example, people who
cannot understand information
designed to help them are, as a
consequence, more vulnerable
than those who can.
These and other learning dif-
culties make it harder to nd out
about and/or understand infor-
mation related to data (e.g., their
rights, privacy laws) and ICTs.
Indigenous groups Such groups may be under threat
or experiencing declining num-
bers, and may require protection
for their heritage.
Provenience data – on the origin,
ownership and custody of objects
– is not always captured by ICTs; in
other cases, indigenous people’s
knowledge may be stored without
their knowledge or approval.
The Sámi7As a minority group living in one
of Europe’s harshest regions, the
Sámi experience many forms
of vulnerability. A report by the
United Nations Special Rappor-
teur on the rights of Indigenous
Peoples concluded that Sweden,
Norway and Finland do not full
their stated objectives of guaran-
teeing the human rights of the
Sámi people.8
The Sámi have always been targe-
ted for different types of research,
including register- and biobank-
based research. These projects
have sometimes bypassed ethical
considerations, for example by
failing to communicate fully that
a project is targeting the Sámi
people.
Ethnic minorities Ethnic minorities in a country
often face discrimination and
may exhibit a higher prevalence
of several types of vulnerability
(e.g., low income, low education,
health issues, language barriers).
They may have lower access to
information about their data rights
(e.g., if it is not available in their
rst language).
Refugees Refugees often face discrimina-
tion and may exhibit a higher
prevalence of several types of
vulnerability (e.g., low income,
low education, health issues,
language barriers).
They may be reluctant to provide
personal data due to concerns about
its misuse. This may exclude them
from the potential benets that ICTs
can offer.
Alternatively, they could feel compel-
led to provide personal data even
when they shouldn’t, for fear of not
having access to certain services.
7. The Sámi are the only European people on the UN’s list of Indigenous Peoples.
8. See: www.iwgia.org/en/sapmi.html
20
ICTs, data and vulnerable people: a guide for citizens
Asylum seekers Asylum seekers may experience
mental health issues or trauma,
for example if they have ed a
warzone or catastrophe.
They may be reluctant to provide
personal data due to concerns
about misuse. This may exclude
them from the potential benets
that ICTs can offer.
Migrants The nature of migrants’ vulne-
rabilities varies widely. Poorer
migrants may experience many
of the vulnerabilities that refu-
gees and asylum seekers face,
while high-income migrants may
experience very different vulne-
rabilities (e.g., stress, resentment
among the local population).
Language barriers may increase
the risk of their personal data
being misused. Also, data and ICT
regulations in their new country
may differ to those they are used
to.
Members of Traveller
communities
Traveller communities often face
discrimination and may nd
themselves outside of formal
support systems (e.g., schools,
healthcare).
They may be reluctant to provide
personal data due to concerns
about misuse. This may exclude
them from the potential benets
that ICTs can offer.
Members of the Roma
community
The Roma have historically been
persecuted across Europe, which
leaves many Romani more
vulnerable than other popula-
tions, in terms of low incomes
and employment levels, threats
to their welfare, and many other
forms of vulnerability.
They may be reluctant to provide
personal data due to concerns
about misuse. This may exclude
them from the potential benets
that ICTs can offer.
Sick or injured people,
including hospital patients
Health issues make people
immediately vulnerable, and can
exacerbate other types of vulne-
rability (e.g., loss of income).
They may not be able to give
consent to how their data is used,
for example if they are sedated,
confused or unconscious. Or, they
may give consent too easily, for
example if they want the medical
research to make them better (a
form of temporary vulnerability).
21
ICTs, data and vulnerable people: a guide for citizens
People with chronic and/or
long-term conditions, or
multiple chronic conditions
Vulnerabilities are determined
by the nature and severity of the
condition. For example, many
such conditions will reduce
people’s ability to work and earn
an income.
These people are often exclu-
ded from online information,
depending on whether inclusive
ICT tools are implemented and
available. For example, people
with epilepsy may be vulnerable
to exclusion from certain online
non-inclusive resources due to
ashes/light from screens (photo-
sensitive epilepsy).9
People living in residential care People living in residential care
(also known as assisted living)
have many day-to-day decisions
taken away from them. This lack
of control over their lives can
increase their vulnerability in
many ways (e.g., their diet, their
healthcare, their nances).
For many people in residential
care, data about them may be con-
trolled by others, such as family
members or staff at their residen-
tial home. This reduces their ability
to control, or even inuence, how
their personal data is used.
People with disabilities and
disorders, either physical or
mental (or both), and both
temporary and permanent
Vulnerabilities are determined
by the nature and severity of the
disabilities and disorders. As an
example, people with limited
mobility may be dependent on
others, increasing their vulnerabi-
lity to exploitation or neglect.
Some disabilities may mean
people need assistance to access
or share data, or to understand
privacy statements and give their
consent. This reduces their control
over their own data privacy.
People with limited commu-
nications capacity, such as
speech impediments
Limited communications capacity
prevents people requesting,
or contributing to, information
in a range of scenarios. This
may mean their needs, views or
expectations are not fully consi-
dered (e.g., in public debates).
Some limitations in communica-
tions capacity may mean people
need assistance to access or share
data, or to understand privacy
statements and/or give consent.
This reduces their control over
their data privacy.
9. There are free online tools that perform photosensitive epilepsy analysis; see, for example, www.w3.org/TR/WCAG20-TECHS/G15.html;
Mozilla’s website also has a section on accessibility solutions for developers: https://developer.mozilla.org/en-US/docs/Web/Accessibility/
Seizure_disorders
22
ICTs, data and vulnerable people: a guide for citizens
Visually impaired or blind
people
While many provisions exist for
visually impaired and blind peo-
ple, these may not be available
or affordable for all people, incre-
asing their vulnerability.
They are likely to use software
that reads the screen to them,
which reduces the privacy of that
information. Furthermore, they
might nd their access to infor-
mation restricted, for example if
the websites to which they need
access don’t allow the software to
read everything (e.g., options in
tick boxes).
People excluded by language,
or facing language barriers
People who do not speak the
language of their country of resi-
dence (e.g., some migrants and
refugees, or minorities such as
Creole speakers in Portugal) have
reduced access to information
about support measures, which
increases their vulnerability.
Non-native speakers within a
country, or minority language
speakers, often lack information
in their own language about their
digital rights.
People who are not uent in
English
As English is the predominant
language across Europe, certain
information may only be avai-
lable, or more prominently
available, in this language. Those
who cannot speak or understand
English may nd themselves at
a disadvantage compared with
those who can.
Much of the information on data
rights and privacy is in English,
putting these groups at a disad-
vantage. They are also likely to nd
they have lower access to share
their views on how ICTs develop
and progress, if surveys and deba-
tes are in English.
Children, dependants, minors Younger people are inherently
vulnerable, lacking many of the
attributes that reduce vulnerabi-
lity (e.g., size, strength, comple-
ted education, independence,
income).
Young people cannot legally con-
sent to the use of their data. They
may not know how to complain
about misuse of their data, or be
aware that they can.
Emerging adults (aged 18-25) In many countries, this age
group struggles to access the
advantages that older genera-
tions did, such as secure and
well-paid jobs, or affordable
housing.
A lack of employment and/or
housing may make it harder to
access information about digital
rights and ICTs (e.g., due to the
lack of internet access at home).
23
ICTs, data and vulnerable people: a guide for citizens
Early adults (20-40) In many European countries
(e.g., Portugal, the Netherlands),
people in this age group have a
higher tendency to be self-
employed or freelancers. As
such, especially during moments
of crisis (such as the Covid-19
pandemic), they are vulnerable
to dramatic changes in their
income. They may also have
young families, and hence have
an increased level of vulnerability
(e.g., nancial).
Conversely, they may potentially
have higher levels of technical
skills and education than other
age groups. This means they are
less likely to be vulnerable to
legal and ethical issues around
data privacy, ICTs and their digital
rights.
Older, frail or incapacitated
people
Old age is an inherently vulne-
rable stage of life, as people
often become weaker and more
dependent on others.
While old age is not always linked
to digital illiteracy, there may be
lower awareness of legal and
ethical issues around ICTs, data
and privacy among older people,
compared with the ‘digital gene-
ration’ who have grown up with
this technology.
People who are unemployed
or underemployed, both in the
short term and the long term
Unemployment exacerbates
other forms of vulnerability,
especially nancial vulnerability
and housing. It may also lead to
health and mental health issues.
Unemployed people may miss
out on ICT training and informa-
tion provided through workpla-
ces. They may have no online
access at home (for nancial rea-
sons), meaning they are unaware
of information about ICTs, which
is increasingly shared online.
People who have low
economic status
Similar to unemployment, low
economic status exacerbates
other forms of vulnerability,
especially nancial vulnerability
and housing. It may also lead to
health and mental health issues.
People in this group may have
no online access at home (for
nancial reasons), meaning they
are unaware of information about
ICTs, which is increasingly shared
online.
24
ICTs, data and vulnerable people: a guide for citizens
Social care clients and
beneciaries
People in social care may expe-
rience many other forms of vul-
nerability (e.g., poor health, low
income, insecure housing).
People in this group may lack
access to ICT training and informa-
tion provided through workplaces,
and/or may have no online access
at home (for nancial reasons),
meaning they are unaware of
information about ICTs, which is
increasingly shared online.
People who are illiterate Much of the information that
governs our lives and aims to
support us is provided primarily in
written forms. Illiteracy is a major
barrier to accessing this, leaving
these people vulnerable. Illiteracy
may also be a factor in people
having lower economic status.
A lot of information about legal
and ethical issues around ICTs is
shared in written form, especially
online. Illiteracy means people will
be less aware of, and less able to
understand, this information.
People who are digitally illitera-
te, or who have limited techno-
logical expertise
Much of the information that
governs our lives and aims to
support us is increasingly provi-
ded online; for example doctor’s
appointments that are only
bookable online, or information
that is only shared through social
media.
These people are at risk of being
left behind as information and ser-
vices increasingly move online.
Ofine communities This is not the same vulnerability
as digital illiteracy: it is an access/
infrastructure issue, rather than a
skills/capacity issue. However,
ofine communities will face
many of the same vulnerabili-
ties as those who are digitally
illiterate.
These people are at risk of being
left behind as information and ser-
vices increasingly move online.
Those with limited access to
public infrastructure
As an example, people in rural
areas in some countries lack
good access to infrastructures
such as hospitals, libraries, strong
broadband, childcare, and other
support systems. This makes
them relatively vulnerable, espe-
cially during crises such as the
Covid-19 pandemic.
Lack of infrastructure may extend
to limited internet access (e.g.,
weak or expensive broadband)
and other ICT services. This can
reduce people’s access to informa-
tion about their rights related to
ICTs, data and privacy.
25
ICTs, data and vulnerable people: a guide for citizens
Communities that remain
outside of research processes
Science and research underpin
many elements of society, such as
healthcare, governance and edu-
cation. By being outside of these
processes, either as researchers
or data subjects, these communi-
ties nd their lives inuenced by
research processes in which they
have no stake or voice. As a result,
policies informed by research
may not address their particular
needs or reduce their specic
vulnerabilities.
This is also true for ICT-based rese-
arch: communities with no stake or
voice in the process, or no access
to the ndings, may nd that the
impacts of such research (e.g.,
policy and funding decisions) do
not address their needs or support
them. For example, online surveys
or questionnaires are an increa-
singly common research method
– but almost totally exclude ofine
communities.
People hit by phenomena
beyond their control
Extreme events or phenomena
can cause unexpected vulnera-
bility. While these may be natural
disasters (e.g., volcanoes) or
extreme climate events (e.g.,
droughts, oods), they can also
be life events (e.g., unexpected
illness, accidents, loss of employ-
ment, and death in the family).
The unexpected nature of such
events makes it difcult to prepa-
re for them, leaving people less
resilient.
In the aftermath of a crisis, people
may be tired, stressed or con-
fused, and therefore share their
personal data more easily (i.e., with
less attention) or do so to access
certain services (e.g., post-disaster
support, emergency healthcare).
A recent example is the Covid-19
pandemic, in which personal
freedoms and privacy issues were
often put aside to combat the
spread of the virus.
Any citizen who, for any reason,
considers themselves to be
vulnerable
The nature and severity of this vulnerability, whether ICT related or
otherwise, depends on the perception of the subject. However, it is
important to recognise that vulnerability is not a simple, measurable
issue, but can be subjective, hidden and personal.
Source: Adapted from the report of the COST Action/PANELFIT workshop held in Berlin in March 2020; supplemented by the other resources
listed at the end of this guide.
26
ICTs, data and vulnerable people: a guide for citizens
What can you do?
It is clear that vulnerable people should receive more attention in relation to ethical and
legal discussions around ICTs, and there should be greater efforts to include them in the
development and deployment of ICTs and new other technologies that will affect them (e.g.,
Articial Intelligence). Ideally, there should be specic safeguards to protect vulnerable
people in terms of their data privacy and how data about them is used.
However, as noted, it is difcult – maybe even impossible – to create a denitive list of all vul-
nerable groups in society. It is not even desirable, due to the dynamic nature of vulnerability
and the risk of oversimplifying the complexity of people’s situations, or increasing the risk of
stigmatisation. As such, specic safeguards for vulnerable people’s digital rights may take a
while to come into effect – if they ever do.
In the meantime, there are actions that all citizens can take to ensure that vulnerable peo-
ple’s digital rights are met. Figure 1 outlines a series of actions.
27
ICTs, data and vulnerable people: a guide for citizens
Who?
All citizens, including vulnerable citizens and those who have responsibility for vulnerable citizens
When someone requests your data, check the following: Who are they? What will they use it for?
How long will they keep it? Who will they share it with?
If data controllers provide you with information (e.g., terms and conditions, consent forms), check:
Do you understand it?
If not, ask for a version that is easier to understand (e.g., in your rst language).
If you are still unsure or unhappy about how your data will be used, nd out more. This could be
through a citizen’s advice ofce, or your national data protection authority.
In most cases, you have the right to withdraw consent to your data being used. Before sharing
your data, check: How do I withdraw consent later on? Who do I need to contact?
Figure 1. Actions for data subjects
There are also specic actions that data controllers can take to protect vulnerable data
subjects. Figure 2 illustrates some of these.
Figure 2. Actions for data controllers
28
ICTs, data and vulnerable people: a guide for citizens
Who?
Researchers, employers, companies, authorities, project organisers, etc.
At the start of the process, ask: Who are the vulnerable data subjects in my project, process or task?
How are they vulnerable?
Consider the risks that the members of each vulnerable group will face when you use their data –
and think about how these can be reduced or overcome.
When asking vulnerable citizens for personal data, check: Have they understood what their data
will be used for? How can I make it simpler for them to understand? Have they really given their
consent to its use freely?
Don’t look for concrete solutions, or see addressing vulnerability as a ‘box to be ticked’ in your
project. Instead, see it as an ongoing process that you should review regularly.
Think about data protection for vulnerable groups at every stage of the project:
Does this activity pose a risk to vulnerable groups? How can I address this?
29
ICTs, data and vulnerable people: a guide for citizens
Useful resources
There are several organisations, websites and projects dedicated to helping people under-
stand their rights in our increasingly digital world, and which support vulnerable groups in
different ways. If you are keen to nd out more about the subjects discussed in this guide,
we recommend the following.
Vulnerable people and groups
Statewatch encourages the publication of investigative journalism and critical re-
search in Europe in the elds of the state, justice and home affairs, civil liberties,
accountability and openness. Available in English.
www.statewatch.org
The Social Protection and Human Rights website contains a guide to disadvantaged
and vulnerable groups in society. Available in English.
https://socialprotection-humanrights.org/key-issues/disadvantaged-and-vulnerable-groups/
These videos from the Web Accessibility Initiative explore the impacts of greater
web accessibility, and the benets for everyone, with examples from a variety of
situations. Available in English.
www.w3.org/WAI/perspective-videos/
Legal and ethical issues around ICTs, data and privacy
The Global Data Justice project focuses on the debates and processes occurring
around data governance in different regions, drawing out the overarching principles
and needs that can push data technology governance in the direction of social justi-
ce. Available in English.
https://globaldatajustice.org/
Data Justice Lab examines the relationship between ‘datacation’ and social justice,
such as the politics and impacts of data-driven processes and Big Data. Their website
contains helpful publications and news of upcoming events. Available in English.
https://datajusticelab.org/
30
ICTs, data and vulnerable people: a guide for citizens
Access Now’s digital security helpline works with individuals and organisations
around the world to keep them safe online. If you’re at risk, they can help you
improve your digital security practices. If you’re already under attack, they provide
rapid-response emergency assistance. Available in Arabic, English, French, German,
Italian, Portuguese, Russian, Spanish, Tagalog.
www.accessnow.org/help/
Tactical Tech’s Data Detox Kit provides everyday steps you can take to control your
digital privacy, security and wellbeing in ways that feel right to you. Available in 35
languages.
https://datadetoxkit.org/en/home
Consent Commons is a system of icons that summarises the legal information about
consent that is collected when data is gatheredfrom individuals in online environ-
ments and apps. Available in Spanish.
https://consentcommons.com/
The Future of Privacy Forum and the FPF Education and Innovation Foundation are
catalysts for privacy leadership and scholarship, and advance principled data practi-
ces in support of emerging technologies. Available in English.
https://fpf.org/resources/
The European Digital Rights network defends fundamental rights in the digital age,
advocates for appropriate laws and policies, and raises awareness of the key issues
impacting digital rights. Available in English.
https://edri.org/
Privacy International’s Data Protection Guide contains a wealth of useful information
on issues around data protection. Available in English.
https://privacyinternational.org/report/2255/data-protection-guide-complete
31
ICTs, data and vulnerable people: a guide for citizens
Further reading
If you would like to read more about some of the issues raised in this guide, then we suggest
the following articles as a good starting point.
This article from Privacy International examines how data-driven immigration poli-
cies routinely lead to discriminatory treatment of migrants, with a focus on the UK.
Available in English.
https://privacyinternational.org/long-read/4000/10-threats-migrants-and-refugees
This article on the Data-Pop Alliance website is the abstract of a book chapter, titled
‘Group privacy in the age of Big Data’. It discusses how Big Data is blurring the lines
between individual data and group data, and what can be done about it. Available
in English.
https://datapopalliance.org/item/group-privacy-in-the-age-of-big-data/
This article from the European Data Journalism Network, on ‘The uncountable: How
Covid-19 affected migrants and refugees’ health’ provides an example of how vulnera-
bilities often exacerbate one another. Available in English, French, German and Italian.
www.europeandatajournalism.eu/eng/News/Data-news/The-uncountable-How-Covid-19-af-
fected-migrants-and-refugees-health
32
ICTs, data and vulnerable people: a guide for citizens
Further watching and
listening
The PANELFIT Monthly Chats covered a broad range of subjects around data, ICTs,
privacy and rights. The whole series can be watched again – or, if you prefer, listened
to – via the PANELFIT website. Available in English.
www.panelt.eu/activities/monthly-chats/
This Monthly Chat was specically dedicated to vulnerable populations in the EU
legal framework.
https://youtu.be/fqLfvF-cS70
33
ICTs, data and vulnerable people: a guide for citizens
Acknowledgements
Sources of information used for this guide
The authors collated the information in this guide from the following sources (specic sour-
ces are noted in the text).
Talks and workshops
A COST Action/PANELFIT workshop on ‘Creating a citizens’ information pack on ethical
and legal issues around ICTs: what should be included?’, 9-10 March 2020 in Berlin,
Germany. (www.panelt.eu/2020/06/10/informing-citizens-about-their-data-rights/).
A talk on vulnerable populations by Dr Jedrzej Niklas, Department of Media and
Communications, LSE, UK (formerly University of Leeds), at a PANELFIT workshop,
5 June 2019, in Bilbao, Spain.
Personal communication with Professor Anna Lydia Svalastog, Department of Health
and Social Studies, Østfold University College, Norway.
Personal communication with Professor Iñigo de Miguel Beriain, Department of
Public Law University of the Basque Country, Spain.
Documents
Berti Suman, A and Pierce, R (2018) ‘Challenges for citizen science and the EU Open
Science Agenda under the GDPR’, European Data Protection Law Review 4(3): 284-
95, https://doi.org/10.21552/edpl/2018/3/7 (open access)
Malgieri, G and Niklas, J (2020) ‘Vulnerable data subjects’, Computer Law & Security
Review 37: 105415, https://doi.org/10.1016/j.clsr.2020.105415 (open access)
Milan, S and Treré, T (2017) ‘Big Data from the South: The beginning of a conversa-
tion we must have’, DataActive, 16 October, https://data-activism.net/2017/10/big-
datasur/ (open access)
34
ICTs, data and vulnerable people: a guide for citizens
PANELFIT consortium (2020) ‘D5.2 Critical Analysis of the ICT Data Protection Regu-
latory Framework (Consolidated Version)’, Bilbao, Spain
Peroni, L and Timmer, A (2013) ‘Vulnerable groups: The promise of an emerging con-
cept in European Human Rights Convention law’, International Journal of Constitutio-
nal Law 11(4): 1056-85, https://doi.org/10.1093/icon/mot042 (open access)
Videos and podcasts
PANELFIT podcast with Gianclaudio Malgieri, ‘Vulnerable data subjects and EU Law’,
27 February 2020, www.youtube.com/watch?v=fqLfvF-cS70
35
ICTs, data and vulnerable people: a guide for citizens
We would like to thank the following people for their help in writing this guide:
Alexandra Castañeda, Andreas Matheus, Andrzej Klimczuk, Anna Berti Suman, Annelies
Duerinckx, Christoforos Pavlakis, Corelia Baibarac-Duignan, Elisabetta Broglio, Federico
Caruso, Geon Thuermer, Helen Feord, Janice Asine, Jaume Piera, Karen Soacha, Katerina
Zourou, Katherin Wagenknecht, Katrin Vohland, Linda Freyburg, Marcel Leppée, Marta
Camara Oliveira, Mieke Sterken, Tim Woods
This project received funding from the European Union’s Horizon 2020
research and innovation programme under grant agreement No 788039.
This document reects only the author’s view and the Agency is not re-
sponsible for any use that may be made of the information it contains.
The workshop held in Berlin, March 2020, was organised through a collaboration betwe-
en: the European Citizen Science Association (ECSA), COST Action 15212, the Institute of
Marine Sciences (ICM-CSIC), and the PANELFIT and EU-Citizen.Science projects. Financial
support was provided by PANELFIT (EU grant agreement 788039) and COST Action 15212
(supported by European Cooperation in Science and Technology).
© PANELFIT Consortium (2021)
This work is licensed under a CC BY 4.0 license:
https://creativecommons.org/licenses/by/4.0/
www.envato.com
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