As a funder, the EU requires the submission of a data management plan within 6 months of the start of the research project. However, the data management plan should be prepared as early as possible before the start of the project to ensure that all rights, roles, and responsibilities related to the data are planned in advance. This also ensures that the resources needed for the research, related to the data, are available and that the funder’s requirements for data openness and accessibility can be met.
Early planning of data management is particularly important in studies involving personal data. Participants must be informed about the processing of their data before data collection, and this requires data management planning.
Since EU-funded projects are often more complex than typical research projects and are subject to greater requirements from the funder, data management plans for these projects are prepared in collaboration with the Open Science Centre. The data management template preferred by the EU also differs from the standard data management plan template. While the standard template focuses on practical storage solutions and legal issues, the EU template emphasizes the implementation of the FAIR principles.
In addition to the FAIR principles, the EU applies the principles of open science, requiring the opening of all original research data produced by researchers in the project. If the data to be produced contains personal data, it must be anonymized within the project timeframe. Anonymisation must be carefully planned and resourced. The responsible project leader ensures that personnel and the necessary working time are allocated for anonymization. If anonymization is not possible, openness must be addressed in another way, such as by archiving the data in a suitable repository or justifying why the openness of the research data cannot be implemented according to the funder’s requirements.
These requirements must be taken into account from the planning stage of the project to ensure they can be met in the best possible way.