It is important that you always comply with the information duty when collecting personal data directly from data subjects (e.g. through questionnaires, personal interviews, etc.).

When collecting personal data indirectly, e.g. in register-based research or from social media, in some cases you need not comply with your information duty. You can do this if it is impossible to comply with the information duty, or if you assess that it would require a disproportionate effort.

When assessing whether notifying the data subjects would involve a disproportionate effort, you should balance:

• the data subject's interest in being made aware of the processing, and
• the difficulties in fulfilling the information duty.

In your assessment, you could focus on:

• the number of people
• the age of the personal data
• the compensatory measures, e.g. that you will publish on the research project website how you will process the personal data, and 
• the significance of the different interests (the interests of the data subject compared with research as an important matter of public interest) given the data being processed
• how intrusive your processing of personal data is for the individual data subject.

If you come to the conclusion that meeting the information duty would involve a disproportionate effort, you must instead protect the rights of the data subjects in another way. You can do this by publishing information on how you will process the personal data, e.g. on the research project website or in a profile on social media. 

Note that there are specific requirements for the information you need to give the data subject to comply with your information duty. You may want to use AU’s templates to check what information you need to remember.

There are also requirements for the way you provide the information. The information duty requires that you provide the information:

• in a concise, transparent, easy-to-understand and easy-to-read form
• in plain and simple language (see text example below)
• especially when information is specifically aimed at a child.

Provide the information in writing, or, if appropriate, electronically. If the data subject so requests, the data may be given orally, provided that the data subject's identity can be confirmed in some other way (e.g. presentation of an ID card).

Researchers come into contact with or receive information about data subjects (research participants, informants, subjects, etc.) in many different ways. For example: 

• Recruitment via the internet 
• Recruitment via a leaflet/brochure 
• Meetings with the data subjects at their own premises (e.g. at school, at home, at a company, in hospital, etc.) 
• Social media 
• Extracts from registers 

The way in which, as a researcher, you want to communicate with the data subjects (and thus comply with your information duty) can vary depending on whether you receive the data from the person in question or from others, the type of contact you use, your research method and habits, etc. 

There are examples here of how you can comply with the information duty and integrate it into your other information material. Naturally, you will have to choose the way that makes the most sense and is most transparent for the data subjects in the specific situation.

• As a clickable direct link in connection with a questionnaire, where the participant cannot start answering the form until he/she has read and clicked the box.
• As an appendix to your project information for participants
• As a QR code that links directly to an AU website on which you have uploaded the information
• As part of the text in your information material. Note, however, that the text must be transparent. This means that you must avoid over-complicating information so that the data subject cannot see that it is about your processing of personal data.