How to proceed

If your dataset contains potentially sensitive data, please consult our Step-by-Step Guide on Data Publication for ETH Zurich Researchers. It contains information on the necessary steps to prepare your dataset for publication.

If your dataset contains health-related personal data, we additionally recommend consulting Scientific IT Services before publication.

Any disclosure risk must always be assessed at the level of the individual case. The ultimate responsibility for this lies with the researchers who submit a dataset for publication.

Which potentially sensitive data may be included in the Research Collection?

In addition, use the following table to check whether and under what conditions your dataset can be included in the Research Collection.

Due to legal, security and ethical requirements, the Research Collection is only suitable to a limited extent as a repository for publishing and archiving potentially sensitive data. The following criteria must therefore be observed.

Data typeExamplesCan it be deposited in the Research Collection?
Personal research data that are not subject to the Human Research Act (cf. Art. 3 Data Protection Act) and have not been classified as highly sensitive (cf. below).
  • Transcripts or recordings of interviews in which individuals reveal political or religious views about themselves
  • Completed questionnaires that can be directly attributed to individuals
  • Photographs of identifiable persons
  • Photographs of private spaces (e.g. houses, gardens) or objects (e.g. license plates of cars) that can be assigned to a person without much effort

Yes, provided that the consent of the data subjects has been obtained.

Please refer to the factsheet Data Protection in Research Projects of the Legal Service of ETH Zurich.

Health-related personal data covered by the Human Research Act.
  • Data about an identified or identifiable individual that relates to his or her health or disease
  • Genetic data

Yes, provided irreversible anonymization and consent of data subjects has been obtained.

Please note the following caveats and general conditions:

  • In general, for sharing or archiving health-related data, we recommend using a repository specialized in the preservation of such data. The Research Collection can accommodate such data under the conditions stated here, but does not specialize in handling health-related personal data.
  • Due to the rapid progress of technical methods for de-anonymization, it is controversial whether clinical research data can be permanently and irreversibly anonymized at all. The Swiss Clinical Trial Organisation writes in its 2022 Guidance: [...] clinical research data should rarely, if ever, be treated and shared as anonymized data even after appropriate processing. Researchers should carefully weigh the benefits and risks and, if in doubt, should consider their data identifying" (p. 22). We recommend an appropriate risk assessment before publication.
  • For research projects that involve research with human subjects or the collection of personal data or the use of non-anonymized personal data, an application must be submitted to the ETH Zurich Ethics Committee.
  • Please refer to the factsheet Data Protection in Research Projects of the Legal Service of ETH Zurich.

No, if not anonymized and/or no consent is given.

No, provided it is information that directly identifies individuals (e.g. tables with keys used to de-identify a patient by coding / pseudonymization).

Strictly confidential research data
  • Highly sensitive personal data (personal data whose misuse could endanger the life of the data subject).
  • Unpublished research results that could cause serious harm if disclosed prematurely
  • Research data with contractually agreed secrecy (e.g. with cooperation partners, third parties)
  • Intellectual property (such as technical inventions, program code, etc.) where there is an obligation of confidentiality


We recommend that researchers conduct a risk assessment in accordance with the Directive on Information Security at ETH Zurich to determine the level of confidentiality of their data.

Unpublished research data subject to export controls
  • Software or technologies for military goods
  • Software or technologies for dual use goods


Information on classification can be found on the export control web pages.

Administrative documents

Data documenting administrative processes related to a research project, e.g.

  • Contracts
  • Research plans
  • Accounting records
  • Invoices
  • Documents from personnel administration

Usually no

Such documents are generally not intended for publication or sharing with other researchers, so a public repository is not the most appropriate tool for preservation. We recommend that such documents be archived in an appropriate internal repository of the research group or department.

Further information


Gahl, Brigitta; Haynes, Alan G; Sluka, Constantin; et al. (2022). Sharing of Data from Clinical Research Projects. Guidance from the SCTO’s CTU Network. Published by the Swiss Clinical Trial Organisation (SCTO).

Krügel, Sybil (2019). The informed consent as legal and ethical basis of research data production. FORS Guide No. 05, Version 1.0. Lausanne: Swiss Centre of Expertise in the Social Sciences FORS.

Puebla, Iratxe; Lowenberg, Daniella; FORCE11 Research Data Publishing Ethics WG. (2021). Joint FORCE11 & COPE Research Data Publishing Ethics Working Group Recommendations. Zenodo.

Laws and guidelines

Directive on Information Security at ETH Zurich dated 9 April 2018 (last updated: 1 August 2021) incl. classification recommendation Confidentiality

Factsheet Data Protection in Research Projects of December 2019, Legal Services of ETH Zurich

Federal Act on Data Protection (FADP) of 19 June 1992 (Status as of 1 March 2019) 

Federal Act on Research involving Human Beings (Human Research Act, HRA) of 30 September 2011 (Status as of 26 May 2021)

Ordinance on Human Research with the Exception of Clinical Trials (Human Research Ordinance, HRO) of 20 September 2013 (Status as of 26 May 2022)


ETH Zurich: Export Control

ETH Zurich: Research with Human Participants

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