Screening as a data processing operation in aid work

Closed workshop – Friday 23 September from 09:00 – 12:00 at the Peace Research Institute Oslo

What does screening mean for NGOs and what may it mean from the perspective of screened individuals? How are organisational decisions made (whom to screen, when, how often)? How is screening documented as a data processing operation in the context of General Data Protection Regulation (GDPR)? How are concerned individuals notified? What are the costs and benefits of transparency? Are privacy notices (available on websites) adequate measures to communicate the act of screening from the perspective of GDPR and its transparency principle?

NGOs delivering aid are expected to screen individuals in line with conditional clauses in certain grant agreements signed with their official donors. Screening, however, is not simply a risk mitigating measure in the context of anti-money laundering (AML) and counter-terrorism financing (CTF), but it can also be considered a data processing operation as long as organisations subscribe to tech solutions providing access to consolidated databases (sanctions lists, etc). As such, it should be clearly communicated to concerned individuals – if not to the general public – by providing enough information “in a concise, transparent, intelligible and easily accessible form, using clear and plain language” as prescribed by GDPR Article 12(1) in line with the general transparency principle Article 5(1). Publicly available privacy notices, however, rarely mention it.

The purpose of the workshop was to facilitate a discussion on relevant data protection issues focusing on the principle of transparency, right to information and data subjects’ reasonable expectations. Practitioners were invited to participate in co-creating knowledge on this subject by sharing their experiences and the dilemmas they face.

The event was arranged by Beata Paragi, an Associate Professor at Corvinus University of Budapest, as part of her MA-thesis project hosted by NRCCL/SERI at the University of Oslo. It is funded by the Norwegian Centre for Humanitarian Studies and hosted by two Peace Research Institute Oslo (PRIO) research groups (Humanitarianism and Security).

This was a closed, hybrid event. While a policy paper and an NCHS-podcast may follow the workshop, Chatham House rules applied during the workshop. If you have any questions, please contact or