Introduction

As communicated earlier this year, the Dutch law regarding payments to third parties (IB47 scheme) has changed. This change required researchers to collect BSN and DoB of their research participants in order to reimburse these volunteers. Apart from the administrative burden and privacy risks involved in processing these data, the requirement to collect these data may also have detrimental effects for certain types of research, e.g. through introducing a bias in sample characteristics. Thanks to your input and our collective effort, the university was able to convince the Tax and Customs Administration to grant an exemption to the obligation to collect these data: payments of €50 or less per participant per study now fall under the volunteer scheme for which researchers do not have to collect BSN and DoB.

Payment categories

For more information about all the possibilities for payments (including gifts and raffles) to research participants in- and outside the EU and how to do this, please see here. This webpage also includes a useful decision tree IMPORTANT: it appears this tree is outdated, for payments under 50 euro's use the tile titled "Vergoeding deelnemers onderzoeken tot maximaal €50 / Payment participants research for maximally €50)" instead.

Based on the exemption, we now distinguish three categories of payments to research participants:

1. Bank/VVV voucher payments of max €50: this category falls under the so-called volunteer scheme and does not require the collection of BSN and DoB. Name of the participant is required for VVV and bank transfer. In addition, address and bank details are required for bank transfer.
2. Cash/VVV voucher payments of max €50 that absolutely should not require any personal data (the ‘anonymous’ category): for this type of payment, the researchers need to include a valid justification in their research proposal that is approved by the Ethical Committee, i.e., why reporting the name of the participant when making the payment is detrimental.
3. Bank/VVV voucher payments exceeding €50: this category remains under the IB47 scheme. We must collect and provide the following participant data to comply with the law: full name, street name, apartment/house number, ZIP code, city, country, date of birth, BSN number, and IBAN if relevant. The FSSC (Financial Shared Service Center) will not proceed with payment without this information.  

If you are currently collecting BSN and DoB in your ongoing study that would now meet the criteria of category 1 (volunteer scheme), you may drop the collection of BSN and DoB and amend the procedures and information letter accordingly without informing the Ethics Committee.

Provisionary BSN processing guidelines (IB47 scheme)

While FSW is working with the FSSC/ASSC and the Bestuursbureau (FIN) to develop a structural solution for registering personal data and redesigning the payment process, please adhere to the provisionary guidelines when processing BSN. These guidelines, tools and templates for informing participants and processing BSN are provided here.

Questions?

Although these changes are for the better for most of our research and should reduce the administrative burden and privacy risk, we understand that these changes may raise questions. In case of questions or doubts, please do not hesitate to reach out via bsn@fsw.leidenuniv.nl

Provisionary guidelines

The following is a step-by-step for participant information collection, in the payment categories for which BSN information needs to be collected:  

1. Information letter contents: your information letter must inform participants that data will be collected for payment and tax purposes. Example text can be found here. 

2. How to collect BSN and payment information online: after securing informed consent, you can use a dedicated Qualtrics survey to collect BSN and payment details. A download link and instructions can be found here. We consider Qualtrics to be a safe solution.  

3. How to collect BSN and payment information offline: although we strongly prefer the Qualtrics survey, pen-and-paper forms for collecting BSN and payment information may be used if necessary (template here). Store these forms securely. Do not collect BSN on the paper informed-consent forms. 

4. Collect BSN into Excel file: data collected via Qualtrics survey or pen-and-paper form should be stored in the FSSC’s Excel file for participant payment. You can find the Excel form here. After this has been done, delete the data from Qualtrics or safely dispose of the paper forms.   

5. Store the Excel file: store the Excel file the way you store a key file: secured with a password, with limited access, in a dedicated folder on network storage (J-drive), Sharepoint or ResearchDrive.

6. Submit the Excel file: submit the Excel file to the FSSC as you would usually do: through the service portal (general information, manual). 

7. Archive the Excel file: do not delete the Excel file after payment. The retention period for financial data is seven years. 

The templates will be updated when necessary. Make sure you are using the most current version of documents by consulting this Wiki.

Exceptions to the obligation to collect BSN

Take note of the following circumstances: 

• If participants are awarded €50 or less, BSN collection is not required, see here for details.
• If participants in a new study cannot acquire a BSN, you do not have to collect it. Note that international participants residing and paying taxes in the Netherlands are responsible for acquiring a BSN.
• Participants in an ongoing study for which you did not mention BSN at the time of ethical approval and you already collected the other financial data without BSN. See F.A.Q..
• When participants are recruited through platforms which pay them for their labor, those platforms are responsible for supplying relevant information to the DTCA. You do not have to collect BSN for those participants, regardless of nationality. This is the case for Prolific for instance. 

Privacy and the General Data Protection Regulation (GDPR)

Please note that processing BSN does not violate the GDPR. The GDPR requires a legal ground for processing personal information. In this case, that ground is legal obligation: we process BSN for purposes of legal compliance. If participants have consented to the study and are informed about processing BSN, you do not need consent to process BSN.

Ethics, Committees and the METC

For ongoing studies, submitting an amendment to your respective Ethics Committee is not needed, even if BSN collection was not included in the original submission. We are in talks with the METC to align our approaches.

Contact information

If you have any questions about the above information or feedback, please contact us at bsn@fsw.leidenuniv.nl. This mailbox is monitored by FSW’s controller , policy officer research, privacy officer, and information manager.

Templates

For all templates texts, keep in mind that you adjust the language / wording to fit the target audience. If you are unsure about the final text please contact privacy@fsw.leidenuniv.nl

English Information Letter

Dutch Information Letter

Collection via Qualtrics Survey

The Qualtrics survey template (and instructions) for collecting payment details can be found here.

Collection via Paper-and-Pen Forms

To collect payment details via pen-and-paper, please find a suggested template in English and Dutch, and the key-form here. Important: use a key-form (English, Dutch) to keep a list of internal and external participant codes. Use the external participant code on the payment forms and in communications to the FSSC.

If you print the form on separate pages, you can give the participant the first information page to take home.

After collecting the information, you can fill in the Excel form.

Updates & Timeline

17-08-2022: Important exceptions to the BSN requirements have been approved: compensation of €50 or less per study no longer requires BSN collection.

02-03-2022: (upcoming) meeting with the FSSC and the Bestuursbureau to develop a structural solution for the registration of BSN. 

18-02-2022: Process flow for payment in ongoing studies agreed by the Director of Finance.

16-02-2022: BSN issue addressed on the agenda of the joint Deans of Social Sciences (DSW) by the The National Ethics Council for Social and Behavioral Sciences. DSW will collectively and unanimously take a stand against the Tax Administration and request an exemption position for participants (e.g. under the category of volunteers).

Also the DPO-network of Dutch universities have requested UNL to address the issue.

11-02-2022: We took inventory of ongoing studies at FSW in three categories:

1. Ongoing studies where payment has already been made to participants (and BSN has not been collected so far).
2. Ongoing studies where adding the BSN collection may be technically or practically very difficult.
3. Specific participant groups for which BSN collection may be unwanted or unfeasible.

We provided input to the Director of Finance about these studies for the Tax Administration (see F.A.Q.).

F.A.Q.

We will discuss the practical approaches with the FSSC and update the F.A.Q.