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Data access for science: considering data strategy and register data together

The German Data Forum (RatSWD) welcomes the strong focus on research in the Data Strategy of the German Federal Government. The potential of the scientific use of data for evidence-based policy advice is emphasised, and register modernisation is a crucial part of this strategy. Nevertheless, research clauses are absent in the Register Modernisation Act passed by the German Bundestag. A stronger attention to science in the upcoming and future modernisation of registers creates opportunities for pioneering socially relevant research. The German Data Forum (RatSWD) therefore calls for the research clauses proposed in the data strategy to be implemented in future legislative initiatives.

The German Data Forum (RatSWD) is pleased that the Data Strategy of the German Federal Government [German] adopted on 27.01.2021 emphasises the role of science. This shows that the government recognizes scientific research as indispensable in using existing data beyond individual interests, for the common good of society. Access to data for science, including administrative data, is going to be expanded as well. With regards to new legislative projects, the strategy advises that the extent to which research-friendly, barrier-free access rules (research clauses) can be created for independent scientific research should be examined in the future (see Data Strategy of the German Federal Government, p. 20). Furthermore, the federal ministries should establish or expand research data centres (RDC) in their downstream areas and facilities, if this seems professionally required (p. 61). The data strategy is thus aligned with the tried and tested model of decentralised RDCs established by the German Data Forum (RatSWD), which enable scientists to access research data in accordance with data protection and quality assurance. Overall, important petitions are addressed, which the German Data Forum (RatSWD) laid out in its Position Paper on the key issues of the Federal Government’s data strategy, and at the hearing on the data strategy in the Federal Chancellery on 23.01.2020.

The Register Modernisation Act was passed by the Bundestag on 28.01.2021, just one day after the data strategy was published. With the Act, the first measures of the data strategy regarding register modernisation were taken. However, an opportunity has already been missed here to implement better data access for science in line with the data strategy. Additionally, with regards to the Register Modernisation Act, the tax identification number- which is already kept in relevant registers for determining tax- is to be introduced as an overarching “identifying feature” for other registers, such as in the population register or the civil status register.

Contrary to the numerous appeals from the scientific community, this ID and register data may only be used with a narrow purpose limitation to the official context. Although this is understandable in view of the public discussion, the German Data Forum (RatSWD) would have suggested a little more foresight against the background of the data strategy: given the large number of legislative changes required for the introduction of the ID, the opportunity to add research clauses was passed by. The references made by science to the great potential of data protection-compliant use of register data by scientific research, as it has been common for many years in other European countries, were not taken into account.

Thus, the Register Modernization Act is in tension with the objectives of the Data Strategy of the German Federal Government published shortly before. Even existing sources of information, such as population registers, tax, and education data are only accessible to a limited extent or not at all for scientific research, and some even have to first be set up (e.g., an education register). As a result, scientific potential is limited, and independent policy advice based on empirical evidence is prevented. This harms both Germany as a place of science, and the constitutionally guaranteed freedom of science. It also has a disadvantageous effect for citizens, administration, and the economy, all of which would benefit from innovative and independent research results. Improved data accessibility would not only enable data-based research and sampling in Germany, but also, by analysing register data, international comparisons would be easier to carry out. At the same time, scientists could contribute their data skills to the further development of the registers, and thus improve the quality of the register data used for administrative purposes.

The German Data Forum (RatSWD) requests that access to data for science, as formulated in the Data Strategy of the German Federal Government, be implemented consistently in the future. This can be achieved through research clauses in future legislative projects or- better still- through an innovative “research data law.” In the coming months, a working group of the German Data Forum (RatSWD) will illustrate the potentials and framework conditions of scientific access and linkage of register data, and develop recommendations from this.


The German Data Forum (RatSWD) advises the federal government and the governments in the federal states on expanding and improving the research data infrastructure for the empirical social, behavioural and economic sciences since 2004. The German Data Forum (RatSWD) is made up of ten elected representatives from the social, behavioural, and economic disciplines who work together with ten representatives from key data producers.

The German Data Forum (RatSWD) is part of the Consortium for Social, Behavioural, Educational, and Economic sciences (KonsortSWD) in the National Research Data Infrastructure (NFDI). It acts as an institutionalised forum for dialogue between science and data producers, as well as developing recommendations and opinions. It is committed to supporting an infrastructure that enables sciences to have broad, flexible, and secure data access. These data are provided by state, science-based, and private-sector actors. The German Data Forum (RatSWD) has currently accredited 39 research data centres (as of February 2021), and encourages their cooperation.