Processing neuroimaging data for research purposes : Open Science, FAIR data, and the GDPR

Abstract

Open Science and FAIR (Findable, Accessible, Interoperable, and Reusable) Science have emerged as two prominent, related, often conflated but actually distinct, frameworks supporting data sharing. The neuroimaging community has embraced the Open Science practice of sharing data with few, if any, restrictions. Neuroimaging data, in particular brain MRI data, is intrinsically personal data, and is, in most cases, impossible to adequately anonymize to the standards dictated by the General Data Protection Regulation (GDPR). As such, in the European Union, neuroimaging repositories are likely to process personal data as defined in the GDPR under all circumstances. The aims of open science are hampered by the GDPR’s requirements. European science is at a distinct disadvantage to its American and other global counterparts, due to the disproportionately high regulatory burden that is placed on research institutions and individual researchers who are often ill-equipped to comply.