Go to content

5. Legal and ethical aspects and concerns related to data gathering and reporting

The session focused on legal and ethical aspects and concerns related to data gathering and reporting. It was chaired by Mia Luhtasaari, Senior Specialist, Ministry of Justice, Finland.

5.1. Legal and ethical aspects on collecting data on LGBTIQ people

Marjut Salokannel, Research Director, University of Helsinki
Equality data can be defined as any piece of information that is useful for the purposes of describing, analysing, reasoning about, and making decisions on the state of equality. 
It can be quantitative or qualitative, and it can include aggregate data that reflect in­equalities and their causes or effects in societies. EU LGBTIQ+ equality strategy for 2026–2030 includes improving the data collection and analysis to better understand the real-life experiences of LGBTIQ+ people. 
Specific characteristics of LGBTIQ data include:
  1. Self-identification as underlying principle
  2. Sexual orientation, gender identity, gender expression, and sex characteristics: there are multiple identifications within LGBTIQ categories
  3. The data are extremely sensitive and not to be found in population based administrative registers. There are also limited data in patient records or in combination of registries.
  4. Data must be obtained by anonymous surveys, while data in administrative registers are limited and non-accurate
  5. Within different LGBTIQ categories, the groups are often small and hard-to-reach.
There is a paradox relating to the collection of equality data. In order to reveal discriminating structures in the society, we need to have solid data to be able to analyse, inform policies and correct discriminating practices in the society; make discrimination visible in everyday life. However, collection of personal data based on protected characteristics in terms of anti-discrimination legislation can also expose the persons or groups to discrimination by revealing their identities or singling out them in public. This phenomenon is augmented by the use of new technologies, such as AI which, while maybe not directly using protected characteristics as the basis for their algorithms, can still lead to discriminating practices in profiling people, automating discrimination.
Collection of equality data in the EU legal framework is based on and regulated by:
  • Human rights-based framework
  • Charter of fundamental rights, in particular right to data protection, right to privacy as well as non-discrimination, equality before the law, and respect and protection of human dignity
  • Lisbon Treaties
  • EU general data protection framework and complementary national laws
  • EU and national statistics laws
  • EU non-discrimination law 
Protected characteristics related to non-discrimination in the EU charter (art. 21) are
sex, “race”, colour, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of a national minority, property, birth, disability, age or sexual orientation. In Finland also health and other personal characteristics are mentioned in the Non-discrimination act. Intersectional discrimination is not explicitly mentioned. 

GDPR and collection of data related to protected characteristics

Personal data encompasses both directly and indirectly identifiable data; also inferred data.
Personal data which are, by their nature, particularly sensitive in relation to fundamental rights and freedoms merit specific protection as the context of their processing could create significant risks to the fundamental rights and freedoms.
Special categories of personal data according to GDPR includes personal data revealing
  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • genetic data
  • processing of biometric data for the purpose of uniquely identifying a natural person
  • data concerning health
  • data concerning a natural person's sex life or sexual orientation
Collecting and processing these special categories of personal data is pro­hibited unless falling under the exemption in Art. 9.2 GDPR, e.g., substantial public interest or scientific research or statistical purposes (Art. 9.2.g or 9.2.j GDPR). Such processing must be provided in national or EU level law which respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
The underlying principle of the United Nation’s Human rights-based data collection is Do not harm. The six principles of Human rights-based data collection are:
  • Inclusive data collection
  • Self-identification
  • Anonymization and disaggregation of collected data
  • Transparency of data collection
  • Privacy
  • Accountability of data collection and use
Human rights and fundamental rights based prior informed consent is required when data are collected directly from data subjects; consent to take part in the survey. In practice, consent is often implied by agreeing to take part in the survey. Data processing may be based either on GDPR based consent or law. In both cases, data subjects must explicitly be informed according to the GDPR of the legal basis and of all uses of their personal data and of the ways how they can exercise their rights in terms of their personal data before answering to the survey. Before GDPR, data was collected through consent and now data processing is usually based on law (GDPR 6.1.c or e).

Special features of collecting data from LGBTIQ-persons

Taking part in the survey should always be voluntary, and answering should be anonymous. Web-based anonymous surveys are the best data collection method. The principle of self-identification should be followed. Questions should clearly specify which components are being measured (e.g., sex, gender, gender identity, sex characteristics, and sexual orientation or other intersecting component), and there should be different answering options, including an option to leave an empty answer. There should be space for further elaboration in writing.
Challenges in data collection include how to reach hard to reach communi­ties, and how to collect representative samples. Taking into account intersectional discrimination in everyday life is also challenging. 
The use of survey data must be communicated to the data subjects before the collection of data. The participants must be informed whether the data will be linked with other data, whether the data will be destroyed after the survey, and how the results are published. Furthermore, the participants must be informed whether the data are being collected in identifiable form, and whether the data will be stored in identifiable form or anonymized, and if so for how long. According to the statistics law, non-anonymous data may be further used in a closed technological environment for scientific research when direct identifiers are removed.
The challenge relating to aggregation of personal data collected from small groups in a small country is that the data are hard to anonymize and even harder to disaggregate. Identifi­cation may constitute a real risk to the persons or groups of persons. Therefore, Nordic or EU-wide data sets and (dis)aggregation are recommendable. 

5.2. Ethical aspects of public authorities’ possibilities for mutual sharing of information about citizens

Pia Nykänen, Researcher, Department of Philosophy, Linguistics and Theory of Science, University of Gothenburg
Recent proposals suggest giving Swedish authorities greater opportunities to share citizen data between them. These proposals stem from societal problems that one wants to curb, reduce and prevent and from the assumption that increased data sharing is a good instrument for this mitigation and prevention. In addition, technical prerequisites for data sharing are in place. 
The focus in the presentation was on public authorities (and actors who are equa­ted with public authorities in law). 'Information sharing' means information ex­change about citizens between authorities. 'Ethical aspects' include normative and value-related questions, and ethical aspects are closely related to moral aspects.
According to a recent report, 161 actors asked for increased opportunities to access informa­tion about health, care providers, care visits, diagnoses, referrals, medication, etc., i.e., data that typically occurs in health and medical care. About one-sixth of these also request the opportunity to access information concerning genetic or biometric data about a natural person, and slightly fewer also request information about sexual orientation, sex life, gender identity, sexual partners, etc. These requests came from some of the major government agencies, some law enforcement agencies and several actors at municipal and regional level. (SOU 2024:63, p. 323) 
Arguments for increased opportunities for data sharing that were presented included
  • Methodological reasons
  • Administrative reasons
  • Economic reasons
  • Statistical reasons
  • Democratic reasons
  • Epistemological reasons
  • "We already share X, so…”
  • "Others do it"
  • Legal reasons
  • Ethical reasons 

Ethical reasons

The four principles of biomedical ethics by Beauchamp and Childress, first mentioned in 1979, are
  • The principle of autonomy, respecting for the decision-making capacities of autonomous persons.
  • The principle of beneficence, maximizing possible benefits and minimizing possible harms.
  • The principle of non-maleficence, not causing harm to others
  • The principle of justice, treating people according to what is fair, due, or owed
Ethical reasons may also be analysed through three moral frameworks
  • Consequentialist ethics: What is morally right depends on the consequences. Example: Utilitarianism.
  • Duty ethics: Some actions (such as violating privacy) are always morally wrong.
  • Rights ethics: Moral rights must not be violated.
These examples demonstrate that there is not just one ethical perspective, but several. 
From the perspective of justice and equality, increased and/​or expanded data sharing may benefit dis­advantaged groups. However, the distribution of the burden that risks to personal integrity constitute should be considered. An 'additional vulnerability' can be conceived of or perceived as an injustice.

Privacy, proportionality, and legitimate purposes

All legislative proposals that include the processing of personal data should (in Sweden) be analysed from a privacy perspective. Privacy analysis is an assessment of whether the con­sequences of the personal data processing are necessary and proportionate. Examples of questions from an ethical and political-philosophical point of view include: What are "purposes that are acceptable in a democratic society?", What are "goals of general interest”?,
How do different proposals for increased and/or expanded data sharing fare regarding such objectives?, Are there tensions between short-term good and long-term good?
Arguments against increased and/or expanded opportunities for data sharing include counterproductive behaviour from citizens, decreased trust in authorities, and "The three M's": Misuse, mistakes, misjudgements. Moreover, additive and cumulative effects could compromise proportionality.
Different ethical and political-philosophical aspects need to be included when proposals for increased and/​or expanded data sharing are analysed. Further research is needed on the effects on trust of increased and/or expanded data sharing, and on how proportionality assessments have been and should be done (in relation to which values and why). 

5.3. Ethical issues in using diverse data when studying LGBTIQ+ experiences 

Riikka Taavetti, University Lecturer, University of Turku and Outi Lepola, Postdoctoral Researcher, University of Turku
When LGBTIQ+ issues are addressed with surveys intended for the wider population, there tends to be relatively few LGBTIQ+ respondents. As a result, especially if multiple options are given for defining one’s gender and sexuality, the groups become too small to be addressed in the analysis.
A common solution to having few respondents is to combine diverse groups in the analysis, for example grouping gender and sexual minorities together. However, the issues these groups face are rather different, and the grouping may, in fact, be mis­leading. Utilizing broader terms or acronyms as LGBTIQ+ may also create the problem of false inclusivity. As an example, does the study actually involve anything on, e.g., intergender people? Another issue is who are addressed with their own letters in the acronym and who are included in the ‘+’?
One option to utilize survey data of even very few LGBTIQ+ respondents is to analyse it with a more qualitative approach on quantitative material. For example, this can mean analysis of single survey answers, including seemingly impossible combinations or rare answers. These methods can offer perspectives to what the survey was not able to cover and can also highlight the implicit assumptions in the survey.

What is considered as sensitive

In ethical evaluation of research, harm is often perceived from a majority (cisgendered and heterosexual) perspective. Those in minoritized positions often face the issues addressed in research, such as discrimination or exclusion, in their daily lives, even if these would be exceptional for the majority. Therefore, addressing them in research might not cause harm but rather give an opportunity to address and analyse these experiences. In ethical evaluation, sexuality is seen as a sensitive personal feature, but often only in relation to minorities – and sometimes unnecessarily.

Ethical questions on (not) being a (partial) insider

One ethical question related to LGBTIQ+ related research is whether the researcher should be an LGBTIQ+ person. There is a historical change in how the insider status is perceived, ranging from whether it has been considered as a problem to seeing it as a requirement, and there are differen­ces between disciplines. Researcher’s positionality may create trust even in surveys: It is not as much a question of researcher’s identity but of familiarity with the themes studied and how this positionality is communicated to the respondents. However, insider position is always partial – there are intersecting differences within the LGBTIQ+ minorities. Insider positionality may reduce unnecessary discretion, but there may also be a danger of imagining understanding the inter­viewee too easily. These are important ethical considerations to keep in mind particularly when doing qualitative interviews.

5.4. Non-binary data gathering & reporting in Iceland

Aró Berg, treasurer, Trans Island
The act on gender autonomy was passed in Iceland in 2019. Based on it, any person from the age of 15 years has the right to change the gender registration in the national registry with­out needing medical interventions or diagnoses. The Act also formalizes two specialized transgender health teams (based on age) within the healthcare system. People can choose their first names regardless of their gender. The Act also bans most unnecessary medical interventions on intersex infants when they can't give consent.
 Based on the law, all forms and data­bases across public and private sectors allow for neutral gender registration. The option to register one's gender as neutral was adopted at the beginning of 2021. From 2022, the number of non-binary people has tripled. The total population of Iceland is around 400,000 people, and currently 217 individuals are registered non-binary. However, not everyone who are non-binary change their gender registration, for example if they do not want the X gender marker in their passport.
Data gathering and reporting must also adhere to the GDPR, one aspect being protection from direct or indirect identification. Because of this, results or indicators are rarely reported separately for non-binary people. Instead, non-binary data are generally randomly distributed between men and women before the data is reported. When the sample size is large enough and the data is not sensitive, the non-binary category is sometimes included. It could be argued, however, that statistical authorities are sometimes too cautious in this regard. Some­times they choose not to include non-binary data in small samples, even when the data is not sensitive at all. As statistics are crucial for providing a foundation for all kinds of societal information and for the detection of inequalities, this lack of reporting is a problem.
Currently, researchers at the University of Iceland are conducting research about how non-binary people prefer to be asked about their gender in surveys and how they want to be represented in data when it's reported. This is the first research of this kind in Iceland. So even though Iceland has the option to register gender neutrally, there is still work to do in data gathering and reporting.