Privacy Statement OKO Public Health Monitor Youth 2024

At least once every 4 years, the Municipal Health Service (GGD) conducts research into the health, well-being and lifestyle of youth on behalf of the municipality. This is described in the Public Health Act (Wpg). An additional health monitor will take place during November 2024. This additional ‘Growing up in a Promising Environment’ Public Health Monitor Youth 2024 (hereinafter referred to as the OKO PHM Youth 2024) will take place, just like the regular Public Health Monitor for Youth, in years 2 and/or 4 of secondary education and will be carried out by the GGD Haaglanden.

The OKO PHM Youth 2024 will be carried out by the GGDs for the municipalities that participate in the OKO prevention approach. The GGDs do this at the request of the participating municipalities. GGD GHOR Nederland (the national umbrella organization of GGDs) supports the GGDs in the execution of this monitor, so that it is executed in the same way nationwide and results can be compared between municipalities. It is an additional measurement, in addition to the 4-yearly cycles.

This research is conducted via a digital questionnaire that the students complete in class at school. No login code or other means are used to determine who completed the questionnaire. In other words, it is not possible to trace who completed the questionnaire. Participation in the questionnaire is not mandatory. However, it is appreciated if the questionnaire is completed. This helps to gain insight into the health situation of students in class 2 and/or 4 and health policy can be drawn up to ensure that the health situation of young people is promoted.

Principles

The OKO PHM Youth 2024 is based on the principle that no personal data is collected, but traceability cannot be completely ruled out in all situations. In this privacy statement, GGD Haaglanden and municipality Wassenaar describes how it handles the completed questionnaires in the OKO PHM Youth 2024, the resulting research results and how the GGD ensures that these are properly protected.

Aims OKO PHM Youth 2024

The OKO PHM Youth 2024 aims to:

  • Have insight into the health situation of youth in class 2 and 4 of the regular secondary education.
  • Contribute to local and national policy to promote health, well-being, and lifestyle of youth.
  • Bring the health situation of young people to the attention of schools and encourage them to develop targeted preventive health policies.

Does GGD Haaglanden process personal data of me/my child and if so, which?

In order to conduct the research and achieve the aims, GGD Haaglanden will use digital questionnaires that collect data about you. The OKO PHM Youth 2024 does not ask for personal data, such as name and address, which means that in principle a student cannot be traced. We do want to know where the student lives, because reports are made for municipalities, which is why we ask for the zip code. In very exceptional situations – through a combination of the completed questions – a student can still be traced. This is an unwanted side effect and certainly not the aim of the research. The GGD ensures that this risk is limited to a minimum by taking the adequate security measures.

The questionnaires deal with the following subjects:

  • Personal data; class, education, age, gender, zipcode (4 digits), place of residence
  • Living arrangements and financial situation
  • Perceived health
  • Happiness, mental health, resilience, trust in the future, loneliness, stand up for yourself, stress
  • School experience
  • Leisure activities
  • Major events (including informal care)
  • Exercise, alcohol use, smoking, cannabis use
  • (Cyber)bullying, sexting
  • Gaming and social media use

You can view an example of the OKO PHM Youth 2024: www.wassenaar.nl/opgroeien-in-een-kansrijke-omgeving-oko

How will GGD Haaglanden and municipality Wassenaar use the data provided in the questionnaires?

Based on their public task, the GGD Haaglanden prepares reports for municipalities and schools, based on the collected data. These reports do not contain any traceable personal data of a student because the reports are drawn up, not at individual level, but at group level of students. These reports ensure that the municipality has insight in the health situation of young people in year 2 and/or 4 of secondary education. On this basis, health policy can be drawn up that promotes the health situation of young people.

Basis for implementation of the OKO PHM Youth 2024

GGD Haaglanden is conducting this research in order to carry out a public task, namely monitoring public health based on the Public Health Act (Wpg) (Article 2, paragraph 2, sub a and b of the Public Health Act).

For processing special personal data, the regional GGDs have a basis in Article 9, paragraph 2, sub i of the GDPR, which states that data processing is necessary for the performance of a task of general interest. This task is elaborated in the Wpg, as stated above.

When carrying out the OKO PHM Youth 2024, GGD Haaglanden only uses the data that are necessary for the performance of the statutory tasks that the GGD carries out on behalf of the municipalities.

Participation in the OKO PHM Youth 2024 is voluntary. Students and/or parents/guardians decide for themselves whether or not to participate in the study. Students can stop the questionnaire at any time. Certain questions can also be skipped if the student does not want to fill them in. The data is saved from the moment the questionnaire is started. If the student wants to stop halfway and does not want the answers filled in up to that point to be saved, the student must go back into the questionnaire and delete the answers. Students receive instructions before they start filling in the questionnaire on how to do this, if desired.

Based on the public task of GGD Haaglanden parents/guardians and/or students may be approached to participate in the study and the answers from the questionnaire may be used.

Who will have access to the data of the OKO PHM Youth 2024?

Within GGD Haaglanden only employees who are responsible for processing the research data have access to the research data. The answers are treated and processed in strict confidence.

GGD Haaglanden uses an external party (Research 2Evolve) to enable the administration of the digital questionnaire and temporary data storage. Research 2Evolve is bound by strict conditions such as security measures and confidentiality.

GGD Haaglanden and the municipality of Wassenaar can decide to share data with third parties for research. In that case, GGD Haaglanden ensures that a student cannot be recognized in the shared data.

How do we protect the data?

The municipality of Wassenaar and GGD Haaglanden are committed to ensuring the privacy of participants. In exceptional cases, it may be possible to trace a student based on the questionnaire. Appropriate measures have been taken to minimize traceability. For each question, it has been determined whether it is necessary for the research and it has been examined whether it is unlikely that the combination will lead to traceability. In the final reports, traceability to a student is not possible.

In addition, all parties take technical and organizational measures to properly secure the completed questionnaires, their dispatch and storage. As stated, only employees involved in the OKO PHM Youth 2024 have access to the completed questionnaires. In addition, the researchers have signed a confidentiality agreement.

How long will the data collected for the OKO PHM Youth 2024 be stored for?

The OKO PHM Youth 2024 aims to monitor the health situation of young people over time. This means that GGD Haaglanden and the municipality of Wassenaar must also have access to the information from the completed questionnaires in the future so that they can achieve the aims described above and continue to carry out the tasks described correctly. GGD Haaglanden stores the datafiles for at least 5 years and then determines their relevance for longer storage every 2 years. The test files, in the possession of the external party (Research 2Evolve), are deleted 2 months after completion of the research.

What are my rights?

The OKO PHM Youth 2024 is based on the principle that it does not use personal data. In very rare cases, a combination of the data entered can make it possible to recognise an individual. However, it is never possible to determine with certainty whether a questionnaire was indeed completed by a specific student. Therefore, in principle, requests relating to the exercise of the rights of data subjects cannot be met. A request to exercise the rights of the data subject can only be processed if it is clearly established that the questionnaire was completed by a student.

Right to refuse

Participation in the OKO PHM Youth 224 is voluntary. Participation can be refused or stopped at any time, without giving a reason. Students and parents/guardians will receive an email from school with information about the study. Both students and parents/guardians can refuse by informing the school. In that case, the student will not complete the questionnaire at school. If a student participates, they will complete the digital questionnaire during a lesson in class. A student can skip questions or stop filling them in. If the student stops filling in the questionnaire, the answers already given will be saved.

Right to information

The student and/or parents/guardians have the right to receive information about the processing of personal data. Therefore, students and parents are informed by email prior to taking the questionnaire. This email refers to this privacy statement.

Right to deletion

The right to deletion cannot be exercised, because one URL is used for all students per school. Individual students are no longer recognizable after sending the questionnaire. As a result, the questionnaire can no longer be deleted.

Right to access, rectification, restriction, and objection

These rights cannot be exercised, because one URL is used per school for all students. Individual students can no longer be recognized after sending the questionnaire. The questionnaire of an individual student can therefore not be found and may/cannot be traced.

Who can I contact with questions?

If students and parents/guardians have any questions about their rights and how they can be exercised in the context of this investigation or wish to file a complaint, they can contact: Data Protection Officer (Functionaris Gegevensbescherming): FG@denhaag.nl
or with the complaints officer (klachtenfunctionaris): klachtenfunctionarisggd@ggdhaaglanden.nl.

If students and parents/guardians have any questions about the research or how GGD Haaglanden handles the completed questionnaires, they can contact the department Epidemiology of GGD Haaglanden, team OKO PHM Youth 2024: gezondheidsmonitor@ggdhaaglanden.nl