Seen and Heard: Young People’s Voices and Freedom of Expression

Erasmus+ Programme KA220-HED - Cooperation Partnerships in Higher Education

Consortium Data Protection and Retention Policy

PROJECT OVERVIEW

‘Seen and Heard: Young People’s Voices and Freedom of Expression’ is a three-year project that seeks to establish the full life cycle (design-implementation-evaluation) of a just and equitable social movement based on youth’s freedom of expression. This is achieved through the design and development of creative protest that places youth at risk of marginalisation and exclusion at the centre of political dialogue, through blended learning experiences and sustained support from researchers, educators, artists, activists, publishers, and policy makers. Its primary research interest is in establishing the relationship of literature to social justice and its role in the engagement of young people in civic and political matters. We also plan to study how literature is positioned in cross-sectoral projects based on human rights initiatives involving young people, while encouraging immigrant and local young people in Malta, Germany, and Poland to create their own protest piece.

The principle activities of ‘Seen and Heard’ include:

an extensive research study on current young adult perceptions of freedom of expression and how literature can modify those perceptions;
a docuseries about local and refugee young people in Malta, Germany, and Poland;
creative protests produced by young people, curated into the basis for a social movement;
in-person and online training and resources for educators, artists, activists, publishers and media makers on how to engage with freedom of expression;
academic open access publication/s discussing the results of human rights education in diverse communities and the role of literature therein;
children’s book/s published with established writers and illustrations and the young participants of the project;
a conference for all stakeholders themed ‘Young People’s Voices and Freedom of Expression’ [Malta, February 2026]

PREAMBLE

In line with the University of Malta’s RDM Policy, the Malta team of the ‘Seen and Heard’ consortium, will follow the FAIR Data Principles (findability, accessibility, interoperability, reusability), keeping data as open as possible to disseminate the knowledge and benefits of this research, as closed as necessary to protect the privacy and anonymity of our participants and the integrity of our research process. We will upload relevant research datasets on the UM Data Repository (DR) and publish processed findings in open access publications. We will request that all project partners liaise with their respective ethics committees and provide evidence of adherence to policy and integrity in the research process.

The General Data Protection Regulation (EU) 2016/679 (GDPR) and the Data Protection Act (CAP 586) regulate the processing of personal data whether held electronically or in manual form. By virtue of a data management plan created and vetted for the purposes of this project, the Project Consortium for the Seen and Heard: Young People’s Voices and Freedom of Expression project is set to fully comply with the Data Protection Principles as set out in these Regulations.

The Project Consortium hereby stands for the University of Malta as lead partner, together with Amnesty International Poland, Humboldt Universitat and University of Wroclaw as partners for the duration of the project, and as long as this Data Protection Policy and the data collected survives. The project started April 10th, 2023 and ends on August 31st, 2026.

Purposes for collecting data

During the course of its operations, the Project Consortium collects and processes information to carry out its obligations in accordance with the present legislation. All data is processed in accordance with the Data Protection Legislation.

Recipients of data

Only employees and service providers who are assigned to carry out the functions of the Project Consortium may access the information that is being processed. Personal data will be disclosed to the personnel within the Project Consortium so that activities, events and initiatives organised by the entity may be promoted and implemented. Disclosure to other departments and third parties may also be made but only as authorised by law.

Your rights

You are entitled to know, free of charge, what type of information the Project Consortium holds and processes about you and why, who had access to it, how it is held and kept up to date, its retention period and what the organisation is doing to comply with data protection legislation.

All data subjects have the right to access any personal information kept about them by the Project Consortium, either on computer or in manual files. The GDPR establishes a formal procedure for dealing with data subject access requests. Requests for access to personal information by data subjects are to be made in writing and sent to the Lead Investigator of the Project Consortium, who is also its Data Controller. Your identification details such as ID number, name and surname must be submitted with the request for access. In case we encounter identification difficulties, you may be required to present an identification document.

The Project Consortium aims to comply as quickly as possible with requests for access to personal information and will ensure that it is provided within a reasonable time from receipt of request, unless there is a good reason for delay. When a request for access cannot be met within a reasonable time, the reason will be explained in writing to the data subject making the request. Should there be any data breaches, the data subject will be informed accordingly.

All data subjects have the right to request that their information is not used or is amended if it results to be incorrect. Data subjects may also request that their data is erased.

These rights may be restricted, if applicable, as per Data Protection Legislation.

In case you are not satisfied with the outcome of your access request, you may refer a complaint to the Information and Data Protection Commissioner, whose contact details are provided here.

COLLECTION

Your personal data is collected through:

1.Fieldwork for the research phase in the project, in secondary school and community settings (e.g. public libraries and gardens) and/or artistic settings (theatre and libraries) in the shape of:

- Anonymous questionnaires for the target participating groups, only featuring numeric data and open ended responses. All questionnaires will be assigned batch numbers to ensure anonymity.
- Observational reflections by researchers during workshops, information sessions and feedback sessions, also with open ended responses.
- A qualitative study run, with numeric and open ended responses to study the making of a docuseries and training programme within the context of the project.
- video interviews with 10 young people chosen from a school that has a diverse demographic of students including Maltese and immigrant children.

In all cases, children and young people will be identified using an invented name that they choose, and educators will be given a choice as to whether they would like to be identifiable or otherwise.

2. Consent in relation to your subscription for receiving promotional material. Opting out will be possible at any time and at no charge.

3. Data subjects are advised that photography and videography may take place at public events organised by the Project Consortium. Images, videos and recordings captured may be disseminated in published material including social media, portfolio work and official reports. The organisation will ensure that safeguards are in place in the capture of such material to ensure the respect to privacy of individuals. Concerns in relation to this may be forwarded to [email protected].

All student, educator and parent/guardian information will be stored according to the EU’s GDPR strategy and only accessed by researchers and artists engaged by the consortium. Participants will be informed of the process and will be asked to sign detailed consent forms, which allow them to withdraw from the project at any time.

Young people will be asked to give permission for their ideas, work, pictures, photographs and/or other data, to be shared beyond the workshop settings for the purposes of this research. Parents and guardians will be asked to give consent on behalf of minors too.

Young people have access to all the materials and research issued as a result of the data collection. A summary of research results in age appropriate language will be prepared for the children and translated into all their respective languages.

The data will be viewed and analysed by the lead investigator in Malta, Poland, and Germany.

RETENTION

The following schedule outlines the retention requirements for the various categories of documentation within the activities organised by Project Consortium within the context of the project.

Type of document	Retention period	Validity/Justification
Personal information of subscribers to the Project Consortium activities and communications (Name, Surname, Email address, etc.)	Duration of the subscription, or until the expiration of the five-year term after the end of the project, whichever comes first.	This is retained until the related consent is removed by the data subject.
Personal information of project participants (Name, Surname, Email address etc.)	Duration of the project and up to five years from project completion.	This allows for the participants to be consulted and accredited for their contribution to the presentation of the final outcome and be informed of similar opportunities or publication.
Photographs and videos of the Consortium’s public events, initiatives and activities	Duration of the project and up to five years from project completion.	The Project Consortium will apply safeguards in the capture of images during such events to respect the right to privacy of data subjects. Requests for erasure will still apply in the event that these images contain personal data.

Data that needs to be destroyed after the noted timeframes will be disposed of in an efficient manner ensuring that such information is no longer available within the Project, with the Project Consortium and its functions.

The Data Protection Officer may be contacted on [email protected].

OTHER CONSIDERATIONS

The Project Lead, Dr Giuliana Fenech and Research Support Officer, Ms Sandy Calleja Portelli are responsible for managing the data collected in Malta and Gozo. They will also ensure that lead researchers at the University of Wroclaw and Humboldt University are managing the primary data collected from the project according to guidelines.

All data will be stored on the University of Malta’s S-Drive in a folder dedicated to Seen and Heard which will only be accessible by the Project Lead and Research Support Officer through their University of Malta staff account. The electronic data will be stored on the University of Malta server whilst the original printed data collected fromthe surveys and workshop will be stored at Dr Fenech’s office as Project Lead.
The Research Support Officer will ensure that all data sets collected are dated and labelled with the dates, WP and Survey numbers, school cohort generic details and any other required metadata. The research support officer will also ensure that no personal details of the students are provided or are visible, except in cases where specific consent is given. Raw data will be stored for five years after the completion of the project, published data will remain available through open access following a process of peer review. Peer review will have two levels – first internally within the Consortium, and then a blind review as per regular academic publisher proceedings.
The research project may access secondary sources of datasets published by NSO (nso.gov.mt) and Eurostat (ec.europa.eu/eurostat). These will be referenced accordingly.
The intellectual property rights for the data are owned by the Seen and Heard Consortium between 2023-2026 and for five subsequent years until 2031.
Methodology of how data was collected throughout the project will be available for sharing with the express written permission of the Project Lead.
The data will not be available for commercial use.
The data collected does not raise any privacy, ethical, confidential concerns, or patent/licensing issues.