Ethics Management Plan

1. Regulatory compliance – Adherence to laws and regulations

NET4Air is carried out in compliance with the provisions of the Grant Agreement concerning Proper implementation of the action (Art. 11), Confidentiality and security (Art. 13), Ethics and values (Art. 14), and Data protection (Art. 15).

The NET4Air Ethics Management Plan is developed based on the laws and regulations relevant for the research and innovation as well as for the ethical issues specific for the project:

Research integrity:

  • ALLEA – The European Code of Conduct for Research Integrity[1]
  • The European Charter & Code for Researchers[2]
  • UNESCO Recommendation on Science and Scientific Researchers[3]

Data protection:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (‘GDPR’)[4]
  • Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data by competent authorities for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, and on the free movement of such data, and repealing Council Framework Decision 2008/977/JHA[5]
  • Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (Text with EEA relevance)[6]
  • Council of Europe – Modernised Convention for the Protection of Individuals with Regard to the Processing of Personal Data (2018) (Modernised Convention 108)[7]

Artificial Intelligence:

  • Proposal for a Regulation of the European Parliament and of the Council laying down harmonised rules on Artificial Intelligence (Artificial Intelligence Act) and amending certain Union legislative acts[8]
  • Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – Fostering a European approach to Artificial Intelligence[9]

2. Ethical principles in NET4Air

The ethical principles guiding the implementation of NET4Air are:

Respect for persons

  • Informed consent.  Participants in project activities are fully informed about the nature, purpose, risks, and benefits of the research before they agree to take part. Through ‘Informed consent’, the project provides clear and comprehensive information in a way that is understandable to the participants, allowing them to make an informed and voluntary decision. Consortium participants must ensure that consent is obtained without coercion or undue influence, and that participants have the capacity to consent.
  • Confidentiality. Protecting the privacy of participants is crucial. This involves ensuring that personal information is kept secure and only used for the purposes agreed upon by the participant. Consortium participants must implement measures to safeguard data from unauthorized access and disclose information only with the participant’s consent or when required by law. Confidentiality also includes anonymizing data to prevent the identification of individuals in any published results.
  • Respect for autonomy. Participants have the right to make decisions about their involvement in project activities without external pressure. Consortium participants acknowledge and honor individuals’ capacity to make their own choices. Researchers must respect participants’ decisions to withdraw from the study at any time without penalty. Additionally, participants should be given the opportunity to ask questions and receive satisfactory answers before and during the research process.

Beneficence

  • Maximize benefits. Consortium participants have the obligation to design and conduct studies that maximize potential benefits to participants and society. Benefits of NET4Air can include advancing scientific understanding, improving health outcomes, or contributing to social well-being in the areas citizens living in big, polluted cities, patients with medical problems related to air quality (asthma, allergies, heart diseases), indoor gas monitoring (explosive, pollutant) for usage in industry, houses, offices and greenhouse gas monitoring.
  • Minimize harm. To the maximum extent possible, the project coordinator will identify potential risks to participants and take steps to reduce or eliminate them. The use of the 100 sensors across the 4 use cases (UC1-City pollution (traffic, buildings) (IoT solution-based mapping); UC2-Indoor monitoring (Large data processing); UC3-Livestock farms (Data acquisition and offline statistics); UC4-Other use cases (forest monitoring, coal burning) (Data acquisition and offline statistics)) will avoid physical, psychological, social, and economic harm to participants.

Justice

  • Avoid unjust selection of participants. Consortium participants must be careful not to exploit participants, particularly those who are vulnerable due to factors such as socioeconomic status, education, or health conditions. The coordinator and WP4 leader will avoid situations where participants might feel pressured to take part in research due to their circumstances and will ensure their participation is voluntary and informed.
  • Equitable selection of participants. The selection process should be fair and based on the scientific goals of the research rather than convenience or bias. The coordinator and WP4 leader should strive to include a diverse participant pool to ensure that the research findings are generalizable and applicable to a wide range of populations.

3. Responsible conduct of research in NET4Air

3.1. Research integrity

NET4Air adheres to ethical principles and professional standards essential for conducting and reporting research. The coordinator will ensure accuracy in data collection, analysis, and reporting, avoiding fabrication, falsification, and misrepresentation of data. To the maximum extent possible, consortium participants will minimize bias in research design, data analysis, and interpretation, and provide clear and complete reporting of methods and findings. Data and materials will be shared as open access to allow others to replicate or build upon the research and the consortium will take responsibility for the validity and reliability of the research. The coordinator will ensure proper supervision and oversight of research activities. Respect for Intellectual Property (IP) will be ensured throughout the project implementation, acknowledging the contributions of others through proper citation and avoiding plagiarism in all forms.

3.2. Artificial Intelligence (AI)

As stated in the Description of Action (GA, p.113), “Internet of Things (IoT) and Artificial Intelligence are going to play an important role in sensors data processing and communication. Key to the advanced evaluation of environment with a focus on air quality is the development of new generations of front-end chemical and biochemical sensors that offer enhanced sensitivity, specificity and reduced footprint/form factor, power, maintenance and that ideally may be wearable by the people. IoT and Machine Learning will also play an important role to establish predictive tools to select meaningful combinations of catalyst modifications as complete experimental assessment of the innumerable permutations is effectively impossible. Machine Learning will also play an important role in developing predictive tools for the identification of possible combinations of catalytic modifications that would increase the selectivity of the sensing layer to a target pollutant, a necessary step as experimental assessment of all permutations is untenable.”

To respond to the EC Ethics recommendation (“The proposal deals with use of AI but this aspect has not been identified in the ethical self-assessment.”), the following ethical guidelines for AI in IoT and environmental sensing are elaborated for NET4Air:

1. User consent and autonomy

  • Informed consent: Obtain explicit informed consent from individuals before collecting data through wearable sensors or other IoT devices, explaining the purpose, usage, and potential risks involved.
  • User control: Provide participants with control over their data, including the ability to access, modify, and delete their information, as well as to opt-out of data collection and processing.

2. Data privacy and security

Confidentiality: Ensure the data collected from sensors, especially when wearable by people, is kept confidential and protected from unauthorized access.

Data anonymization: Implement robust data anonymization techniques to protect individual identities while using and sharing data for analysis and research.

Secure communication: Use encrypted communication protocols to safeguard data transmitted between IoT devices and AI processing units.

3. Safety and reliability

  • Robustness: Ensure AI models and IoT systems are robust, reliable, and capable of functioning under a variety of environmental conditions without compromising performance.
  • Error handling: Develop and implement robust error detection and correction mechanisms to handle malfunctions and inaccuracies in sensor data and AI predictions.
  • Safety protocols: Establish and follow strict safety protocols to prevent and mitigate potential harm to individuals and the environment resulting from AI and IoT applications.

4. Ethical use and impact

  • Beneficial outcomes: Ensure that the deployment of AI and IoT in environmental sensing and catalyst evaluation leads to beneficial outcomes for society, such as improved air quality and public health.
  • Avoiding harm: Actively avoid applications of AI and IoT that could lead to environmental degradation, misuse of data, or adverse social impacts.
  • Public engagement: Engage with the public and relevant stakeholders to understand and address their concerns, fostering trust and acceptance of AI and IoT technologies.

3.3. Geolocation

As stated in the Description of Action (GA, p.109), “NET4Air will make use of personal data, in the form of the geolocation of the participants in the wearable / portable monitoring tool. In order to have valid data for the air pollution mapping in the city, the 100 sensors will be worn by an equivalent amount of users and the system will track the sensors’ location and, inherently, they will provide the geolocation tracking of the respective users. However, all the personal data will be anonymised, and no direct link will be available towards the connection between one user (as a person) and his/her location. Location services will be used solely with the purpose of mapping the air quality.”

To respond to the EC Ethics recommendation (“Geolocation is required for the work and data will be anonymized. It is not clear how this will be implemented nor for what other aims the collected information could be used.”), the following ethical guidelines for NET4Air’s use of personal geolocation data are implemented:

1. Informed consent

  • Transparency: Participants must be fully informed about the purpose of data collection, how their geolocation data will be used, and the measures in place to protect their privacy.
  • Voluntary participation: Participation must be entirely voluntary, with the option to withdraw at any time without any negative consequences.

2. Data minimization

  • Relevance: Only collect geolocation data that is necessary for the purpose of mapping air pollution.
  • Anonymization: Ensure all personal data is anonymized promptly after collection, making it impossible to link data back to individual users.

3. Purpose limitation

  • Specified use: Geolocation data should only be used for mapping air quality and not for any other purpose without explicit consent from the participants.
  • Data usage: The collected data should not be used for monitoring individuals’ behavior or movement patterns beyond the scope of the air quality project.

4. Data security

  • Protection measures: Implement robust security measures to protect data from unauthorized access, including encryption and secure storage solutions.
  • Access control: Limit access to the data to authorized personnel who require it for the purpose of the project.

5. Data anonymization

  • No direct links: Ensure that the data collected cannot be directly linked back to individual participants by removing or obfuscating any identifying information.
  • Anonymization techniques: Use advanced anonymization techniques to further ensure the data cannot be reverse engineered to identify individuals.

7. Participant rights

  • Data access: Allow participants to access their data and provide them with the ability to correct any inaccuracies.
  • Right to erasure: Give participants the right to request the deletion of their data from the system at any time.

4. Participative involvement of citizens (through wearable sensors). Data management ethics

The citizen involvement in NET4Air (WP4) should comply with the following ethical guidelines:

Participation: Obtain informed consent from all participants. Provide detailed information about the project’s goals, methods, and potential impacts. Ensure voluntary participation with the right to withdraw at any time.

Wearable sensors: Inform participants about the types of data collected and their purposes. Ensure sensors are safe and comfortable for long-term use. Regularly review and update the consent process as the project evolves.

Geolocation and data anonymization: Clearly communicate the use and purpose of geolocation data to participants. Implement strict access controls to ensure data security. Use robust anonymization techniques to protect participant identities. Regularly review anonymization methods to address potential re-identification risks. Limit data use to predefined purposes and seek additional consent for any new use cases.

Use of AI technologies: Ensure transparency in AI decision-making processes. Regularly assess AI systems for biases and fairness. Provide clear information to participants about the role of AI in the project.

Data management: Develop and maintain a comprehensive DMP outlining data collection, processing, and storage procedures. Ensure data is findable, accessible, interoperable, and reusable (FAIR). Regularly update the DMP to reflect any changes in data management practices. Implement strong encryption for data storage and transmission. Restrict data access to authorized personnel only. Conduct regular security audits to identify and address vulnerabilities.

5. Ethical review

The independent ethics advisor will review project activities and deliverables to ensure ongoing compliance with ethical standards provided by the NET4Air Ethics management plan. The ethics advisor will adapt and update ethical guidelines in response to new challenges, technological advances, and feedback from consortium participants, research participants and stakeholders. The ethics advisor will provide two ethics assessments during the duration of the project (RP1, RP2) to verify compliance with ethical standards and address any identified issues.

The project coordinator will establish internal policies and procedures that align with these ethical guidelines and ensure all consortium members are informed on these guidelines. The coordinator will ensure that participative involvement of citizens (through wearable sensors) and data management ethics are carried out in accordance with the Ethics management plan. The project coordinator will maintain detailed records of all research activities, including consent forms, data collection processes, and correspondence with stakeholders; will ensure records are stored securely and are accessible for review by relevant authorities during the project implementation and after its end.

Along with the implementation of the Ethics management plan, the following issues will be reviewed by the independent ethics advisor:

Informed consent

  • Clear, concise consent forms are available.
  • Participants are provided with all necessary information about the study’s purpose, procedures, risks, and benefits.
  • Participants understand their rights, including the right to withdraw without penalty.

Privacy and confidentiality

  • Adequate measures to protect the personal data of participants are implemented.
  • Data is anonymized where possible.
  • Data is securely stored, and access is restricted to authorized personnel only.

[1] https://www.allea.org/wp-content/uploads/2017/05/ALLEA-European-Code-of-Conduct-for-Research-Integrity-2017.pdf

[2] https://euraxess.ec.europa.eu/jobs/charter

[3] https://en.unesco.org/themes/ethics-science-and-technology/recommendation_science

[4] https://eur-lex.europa.eu/eli/reg/2016/679/oj

[5] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016L0680

[6] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32018R1725

[7] https://search.coe.int/cm/Pages/result_details.aspx?ObjectId=09000016807c65bf 

[8] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0206

[9] https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM%3A2021%3A205%3AFIN