1. Legal premise

According to article II.2.1 – “General obligations and roles of beneficiaries” – of Annex II of the Grant Agreement, “the beneficiaries b) must comply jointly or individually with any legal obligations they are bound by under applicable EU, international and national law”.

Additionally, in article II.7.2 – “Processing of personal data by the beneficiaries” – of Annex II of the Grant Agreement, it is established that "The beneficiaries must process personal data under the Agreement in compliance with applicable EU and national law on data protection (including authorizations or notification requirements)".

The Project cannot be considered per se as a legitimizing legal basis for the processing of personal data carried out by the beneficiaries.



2. Management of the Project

It is hereby recalled that the project is organized into seven Work Packages (WP):


Project Management will cover all aspects of project management, control and quality to ensure that the project achieves its objectives on time and within the planned budget

Regione Emilia-Romagna


Co-design of the Platform and its Services will carry out an analysis of the landscape concerning Big Data and Artificial Intelligence solutions, models and data. It will co-design the platform and services with stakeholders. Last but not least, the community of stakeholders established in WP2 will be pivotal for carrying out the online and offline interactions foreseen in WP4 and WP5

Boundaryless srl


DT4REGlONS Platform Creation will deal with the development of the platform, including the project searchable repository

Deloitte Technology, S.A.


Mutual Learning and Capacity Building will develop a knowledge base and will implement mutual learning and training activities. Clearly WPA will leverage on the community developed in WP2 and the platform developed in WP3

European Network of Living Labs


Delivering innovative solutions will implement knowledge sharing among stakeholders and will carry out the development of innovative solutions through hackathons. Also this WP will leverage on the community developed in WP2 and the platform developed in WP3

bwcon gmbH


Evaluation, Exploitation and Sustainability, will evaluate the take up and satisfaction of the project platform and services by stakeholders, and will elaborate a sustainability plan of the project results (knowledge base. community, innovative solutions developed) and will also develop a series of policy recommendations and lessons learned concerning the scalability and transferability of the platform.

Fundació Eurecat


Communication and dissemination will receive input from all work packages and will disseminate and communicate the aims, features and results of the project.

European Regions Research and Innovation Network


3. Privacy accountability

The partition of the activities envisaged in the various WPs must be considered as a starting point from a GDPR perspective. In this regard, the close relationship between the processing of personal data related to the aforementioned activities and the related responsibilities, in terms of compliance with the legislation on the protection of personal data, assumes critical relevance.

Therefore, the partners establish that each WP Leader is controller pursuant art. 4 n. 7 of the GDPR  with reference to the processing of personal data related to the WP they are responsible for. In fact, the responsibility each WP Leader holds over the assigned WP requires the said WP Leader to define the most effective organizational and technological measures to protect the rights and freedoms of the interested parties. Additionally, each Partner holds responsibility over the identification of the legal bases relevant to the data processing which is carried out within their own organization. In fact, given the different legal status of the consortium partners, it would be unfeasible to define a "homogeneous" legal basis for the processing of data across WPs and Partners.


4. Information on the processing of personal data pursuant to art. 13 of the GDPR

The project activities are mainly carried out through the DT4Regions platform and at the time of providing the data, the Project Partners provide information on the processing of personal data (also called Privacy Notice). These data are then processed by the Project Partners, based on what is indicated in the following paragraph.

It is possible to request the cancellation of your personal data by writing an email to  or to any of the addresses indicated in the information for the processing of personal data that the Project Partners have provided.

Below are the links to the information for the processing of personal data of the individual Partners who process the data:


5. Sharing of the collected data with the Project Partners

When the Partners collect personal data, they acquire the consent from the data subjects for sharing the same data collected with the Project Partners.

The activities carried out within this project are all aimed at homogeneously raising awareness and giving the widest possible dissemination and therefore to obtain a European Platform for Regions to enable AI and Big Data collective solutions.

The personal data provided, which do not fall within those indicated in articles 9 and 10 of the GDPR, are treated exclusively in compliance with the above. And it is for this reason that a single consent for the sharing of data between the project partners is considered in line with the GDPR It is always possible for data subjects to request the cancellation of personal data by writing to the address indicated in the preceding paragraph or by writing directly to each Partners.


Updated at 18/07/2022