EASA’s Statement on Data Governance in Ethnographic Projects1
This statement describes some of the core methodical and ethical practices of ethnographic research.2
practices have implications for the norms and forms of data management in ethnography.3
We issue this
statement to help ethnographers respond to current mandates for data archiving, storage, and sharing from
governments, universities, and funders.
This statement places ethnographic research within the special clause on “academic expression” included in
Article 85(2) of the GDPR. This derogation has been designed to guarantee the critical social value of
humanities and social sciences research. We call on universities, funders, and academic institutions to fully
execute and implement this special clause in the case of ethnographic research.
1. Ownership: Ethnographic materials are coproduced by researchers and research participants and are
embedded in particular social contexts. A such, they cannot be fully owned or controlled by researchers,
research participants or third parties. The use of standard intellectual property licenses and protocols may
not apply to all ethnographic materials.
2. Archiving: In ethnographic research “data” are always part of a social relationship. It is not easily
reducible to a fixed and finished product. As such, it may not always be possible to archive or store research
materials. In other cases, the archiving of ethnographic materials will require specific technical features (e.g.
different roles for access, editing, sharing or privacy) not available in most institutional repositories.
3. Consent: Ethnographic participation in a social milieu can lead to situations and dynamics that are not
always controllable by researchers and for which it is not always possible (indeed, it is often impossible) to
obtain prior informed consent. Moreover, since research materials are never completely fixed, written
consent can never fully determine its future uses or interpretations as “data”. In contexts of violence or
vulnerability, written consent may violate research participants’ privacy and confidentiality, and even put
them at risk. For ethnographers, informed consent is an ongoing process.
4. Custodianship: Researchers have a scientific and ethical responsibility to preserve and protect the integrity
of ethnographic materials. This is a responsibility that is usually negotiated with research participants. These
forms of custodianship, caretaking or archiving cannot always be anticipated or pre-formatted.
5. Embargo: Researchers have a special duty to consider controlling third party access to ethnographic
materials and retain the rights of embargo and confidentiality over those materials that cannot be anonymized
or turned into data entries.
6. Public access and sharing: The collaborative nature of ethnographic research implies that ethnographers
have a special duty to consider requests by research participants (or their descendants) to share materials,
unless this actively and unnecessarily harms (some of) them. Ethnographers also have a duty to consider
appropriate ways of making research materials publicly accessible when this will not violate ethical
principles of ethnographic research. Making such materials accessible may require special technical features
not available in most institutional repositories.
1 This statement is based on the Leiden Statement on Data Management and Anthropology, as published in Pels et al.
(2018) Data Management in Anthropology: The Next Phase in Ethics Governance? Social Anthropology/Anthropologie
sociale 26/3: 1-23.
2 See the Principles of Professional Responsibility (2012) of the American Anthropological Association and the Ethical
Guidelines for Good Research Practice (2011) of the Association of Social Anthropologists.
3 For an example of a data governance framework for ethnographic research, see Corsín Jiménez, A. (2018) Data
Governance Framework for Ethnography v 1.0, Madrid: CSIC.