How to Cope with GDPR for Graduate Tracking: A Discussion at the Intersection of Law and Policy and Two Solutions

Abstract

Research on higher education, and not only, has used data collected for administrative purposes—register data, to answer various policy-relevant questions. The employability of university graduates is one of such questions, which have been pending, especially in those countries whose higher education massified in the last decades. The promise of register data relies on its objective nature and apparent low cost: researchers are basically processing data that is collected for administrative purposes. In spite of these advantages, register data is still underused. Data protection restrictions, especially the alignment to the General Data Protection Regulation, are reported to temper the thrust towards making administrative data available as micro-data for secondary use. We consider that the policy dialogue would benefit from a transdisciplinary exploration of the solutions found in the EU to counter such reservations to the use of register for research. We propose an analysis at the intersection of policy studies and law of two solutions found in the EU to make register data available to researchers. We attempt to address two related questions: how are the processes designed? How is the GDPR compliance put into practice? We used structured observations of primary and secondary literature to collect our data. Our aim is to enrich the debate surrounding register data as a basis for policy-relevant research and, pragmatically, to indicate policy solutions that can be easily adjusted to national contexts in the EU and put on the table of decision-makers.