Introduce a training program on data protection issues for the personnel involved in the design of the device or system
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This action is one of the most important pieces of advice to be considered from the very first moment of a business development using geospatial data. Its designers (developers, programers, coders, data scientists, engineers) are likely to be unaware of the ethical and legal implications involved in the use of those data. This could bring consequences in terms of adequate compliance with data protection standards.

It is paramount that these key workers have the fullest possible awareness of the ethical and social implications of their work, and of the fact that these can even extend to societal choices.[1] This will help the developer avoid a lot of unnecessary ethical and legal issues. Thus, implementing basic training programs that include at least the fundamentals of the Charter of Fundamental Rights, the principles exposed in Article 5 of the GDPR, the need for a legal basis for processing (including contracts between the parties), privacy by design and by default principles, etc., is an excellent measure in terms of compliance.

However, training people who have never been in touch with data protection issues might be difficult. An alternative/complementary policy is the involvement of an expert on data protection, ethical and legal issues in the development team, so as to create an interdisciplinary team. This might be done by hiring an expert for this purpose (an internal worker or an external consultant) to design the strategy and the subsequent decisions on personal data required by the development of the tools, with the close involvement of the Data Protection Officer.

Adopting adequate measures in terms of ensuring confidentiality, integrity and availability of data is also strongly recommendable (see the ‘Measures in support of confidentiality’ subsection in the ‘Integrity and confidentiality’ section of the ‘Principles’ chapter).


 Developers have checked that tool designers and all those who will have to deal with data have acquired an adequate knowledge of the data protection framework, or they have ensured an adequate involvement of professionals trained in data protection issues in the developing team.

 Developers have introduced a training program on confidentiality, integrity and availability of data issues.

 Developers have involved an expert in ethical/legal uses since the preliminary stages of the research project




1CNIL (2017) How can humans keep the upper hand? The ethical matters raised by algorithms and artificial intelligence. Commission Nationale de l’Informatique et des Libertés, Paris, p.55. Available at: (accessed 15 May 2020).


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