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Improving access to research data: The German Data Forum (RatSWD) comments on the BMBF’s key points on the Research Data Act

The key points paper on the Research Data Act published by the Federal Ministry of Education and Research (BMBF) has met with a generally positive response from the German Data Forum (Rat für Sozial- und Wirtschaftsdaten, RatSWD). In a statement, the German Data Forum emphasises the importance of improved access to research data for science in Germany and makes proposals for its implementation.

The BMBF’s key points paper is an important step towards the urgently needed improvement in scientific access to public sector data. Germany lags behind in international comparison when it comes to data access for research, which makes urgently needed research more difficult. The Federal Government is now taking up the demands of the scientific community in order to remedy this situation with the planned Research Data Act.

The German Data Forum (RatSWD) particularly welcomes the intention to amend the Federal Statistics Act (BStatG) in order to improve access to individual statistical data for research. The German Data Forum calls for the role of the research data centres of the Federal Statistical Office and the federal states to be strengthened through appropriate amendments to the Research Data Act.

A central aspect of the key points paper is the introduction of a German Micro Data Centre as a data trustee. This can only be effective if it provides a technical and organisational infrastructure for the data protection-compliant linking of microdata, the legal basis for this linking is adapted and non-discriminatory access for independent research is also made possible.

Furthermore, the RatSWD is in favour of long-term storage of pseudonymised research data in an archive in order to make important data available for research in the long term. In addition, new regulations in the Research Data Act should ensure research-friendly data protection, which provides for standardised data protection rules across all legal forms and a uniform interpretation of the rules.

In conclusion, the German Data Forum emphasises that the measures proposed in the key points paper address important research concerns. It will now be important to shape the Research Data Act accordingly in order to substantially improve access to data for research in Germany.

The full statement is available for free download on the RatSWD website: https://www.konsortswd.de/wp-content/uploads/RatSWD-Stellungnahme-Eckpunkte-Forschungsdatengesetz.pdf [German only]


The German Data Forum (RatSWD) has been advising the German federal government and the governments of the German states on questions of research data infrastructure for the empirical social, behavioural and economic sciences since 2004. In the RatSWD, ten representatives of the social, behavioural and economic disciplines, legitimised by election, work together with ten representatives of data production.

The RatSWD is part of the Consortium for the Social, Behavioural, Educational and Economic Sciences (KonsortSWD) in the National Research Data Infrastructure (NFDI). It sees itself as an institutionalised forum for dialogue between science and data producers and develops recommendations and statements. In doing so, it is committed to an infrastructure that provides science with broad, flexible and secure access to data. These data are provided by governmental, science-based and private-sector actors. Currently, the RatSWD has accredited 41 research data centres and promotes their cooperation.