Social media data

RESEARCH ETHICS

Utilising social media as research data inevitably involves research ethics questions, challenges, and risks.

As a researcher, your task is to identify the ethical issues and challenges related to social media data and to minimise and manage risks.

Consider the following questions:

• Social media content is generally not intended for research purposes.
  • What risks or harm could arise for individuals from analysing such content?
• What risks or harm could result from processing personal data contained in social media material?
• Could harm occur to you or the individuals if their social media posts are analyzed and highlighted in a public thesis, thereby exposing the posts to a new audience?
• Can you include direct quotes from the material to support your analysis, knowing that the original post and its author may be easily found via search engines?
• Do the posts contain special categories of personal data or other highly sensitive information?
  • Examples of highly sensitive information include: criminal convictions, drug use, financial problems, mental health issues, controversial political opinions and activism.
  • If such information is present, what harm or damage could occur to individuals from being subjects of your research?
  • Avoiding social media material that contains sensitive topics is recommended, as such research may involve significant ethical challenges that cannot be resolved within the scope of a thesis.

These questions, challenges, and risks exist regardless of whether the material is publicly available online or not.

• Please note that researching closed groups likely involves such extensive ethical challenges that they are not suitable as thesis material for Bachelor's/Master's students.
• Even in the case of open groups, it is important to verify whether the platform allows the use of its content for research purposes.
• You must also address other questions related to ethics, personal data, and informing research subjects.

Using social media data often requires preparing a Data Protection Impact Assessment (DPIA).

A DPIA is required especially when the research involves:

• Large-scale processing of data
• Combining or linking datasets
• Collecting special categories of personal data or highly personal information
• Situations where research subjects cannot be informed

More details on DPIA can be found in this educational resource section: Personal Data.

SOCIAL MEDIA CONTENT AND PERSONAL DATA

Social media content almost always includes personal data. In social media, personal data may include, for example, a username, a photograph showing places or people, or a comment containing identifiers.

In other words, when studying social media, you will be collecting and processing personal data. Additionally, you must remember that individuals have the right to know that they are the subject of your research!

Informing and consent

According to the current guidelines of the University of Jyväskylä, you must inform the individuals whose personal data you process and request their consent to participate, even when the data is collected from social media. If it is likely that the research involves commenters or content creators under the age of 15, you must also inform their guardians, and the guardians' consent must also be obtained.

• The guidelines are currently being updated, and the instructions on this page will be revised as soon as updates are available.

Inform

• For example, if you are studying an influencer’s social media channel, send them a privacy notice, research notification, and consent form.
• If you are studying discussion in a social media group that has an administrator, you should first contact the group’s administrator and ask whether you may post a research notification and a privacy notice in the group. Find out how you can ensure the group members' consent to participate in your research.
• If it is impossible or unreasonably burdensome to contact the individual and inform them personally, make the documents available by other means:
  • Publish the privacy notice.
    • Every JYU student has access to a personal JYU webpage which can be used for this purpose.
  • If you are studying comments on a public social media channel or messages on a discussion forum, link the published privacy notice and research notification in the comments section or message thread.
    • State that you are analysing the comments/messages for your thesis.
    • Indicate when you will start and stop monitoring the discussion.
    • Do not start monitoring immediately - give the participants time to delete their messages if they wish.
    • Include your contact details so that participants can reach you later on and request removal of their messages from the dataset.

Ensure consent

• For example, if you are studying a specific influencer’s social media channel, also send them the consent form together with the privacy notice and research notification. You need their response confirming consent.
• In some cases, it is impossible to ensure that research participants give their consent to participate in the study. For example, this may occur if you are examining the comment section of a social media channel and it is not possible to reach all commenters, or if the group of participants may include individuals under the age of 15 whose guardians cannot be contacted.
  • In such cases, the principle of informed consent for participation can be waived, BUT if informed consent is waived, an ethical review is required.
• You can find more information about ethical review in this educational resource section: Personal data.
  • Discuss with your supervisor whether an ethical review is necessary.
  • Familiarise yourself with TENK’s guidelines on the six criteria for ethical review in human sciences.
  • If your research meets even one of these criteria, initiate the University of Jyväskylä’s ethical review process with your thesis supervisor.
  • Before starting the process, contact the university’s Ethics Committee for Human Sciences: ethics-committee@jyu.fi.

These guidelines also apply to social media accounts of public figures, such as politicians, or company accounts.

Legal basis for personal data processing

A privacy notice must always state the legal basis for processing personal data.

• Information about legal basis can be found in this educational resource section: Personal data.
• You can also read about legal basis in the University of Jyväskylä’s Instructions for students, under the section Legal basis for personal data processing and consent.

Legal basis

• If your thesis is a scientific work, the legal basis is public interest.
• If it is a non-scientific work, the legal basis is usually consent.
  • Remember that consent to participate in research and consent as a legal basis for processing personal data are two different things.
  • If you collect data from social media and it is impossible to obtain consent from participants to take part in the research, then it is equally impossible to ensure their active consent for processing personal data.
• If neither public interest nor consent can be used as a legal basis, the remaining option is legitimate interest.
  • Using legitimate interest as a legal basis requires a Balance test.
  • However, legitimate interest cannot be used as a legal basis if social media data is collected directly from individuals, for example, by asking them questions in a discussion forum.

Tip!

Are you interested in studying online discussions but want to avoid handling personal data from a GDPR perspective? Here are some tips on Finnish language options:

• Posts from the Suomi24 discussion forum are available via Kielipankki (Language Bank of Finland).
  • Kielipankki is an archive that stores various language datasets.
  • Some datasets are publicly available, while others require academic login.
  • Certain dataset versions may contain personal data - this is clearly indicated in the license.
  • The license may include data protection conditions, and your project’s published privacy notice must be provided as a link to Kielipankki.
• Comments on newspaper and magazine articles are classified as opinion "letters to the editor", meaning they are considered part of the published article and do not constitute personal data processing.
  • Thus, comments published on the official online platforms or apps of newspapers and magazines are treated as part of the article.

TERMS OF SERVICE AND COPYRIGHT

Review the social media platform's Terms of Service  / Terms of Use.

• The terms may change, so always check the latest version.
• Find out what the terms say about, for example:
  • Downloading and storing content
  • Publicity or public availability of content (not all material found online is public!)
  • Content sharing
  • Copyright
  • Automated data collection (scraping)

Exception for Text and Data Mining

• Section 13b of the Finnish Copyright Act allows for the reproduction and storage of copies of a work for the purpose of text and data mining. Under this exception, it may in certain cases be possible to deviate from the terms of use of a social media platform.
  • “Text and data mining refers --- to an automated analysis technique aimed at analysing text and data in digital form to generate information.” (Translated from: Tekijänoikeuden tiedotus- ja valvontakeskus ry)
  • Mining may be carried out unless the authors have reserved this right. If data mining is conducted for scientific research within a research or cultural heritage institution, rights holders cannot prohibit the mining.
  • A prerequisite for data mining is lawful access to the work.
• If you are considering not complying with the platform’s terms of use based on this exception, consult your supervisor to ensure that your research methods meet the criteria of the exception.

Texts written on social media may exceed the threshold of originality. In addition, copyright protects images uploaded to social media.

• According to Section 25 of the Finnish Copyright Act, it is permissible to cite an image that has been published, i.e., lawfully made available to the public. Thus, from a copyright perspective, image citation allows the use of a legally published work in a thesis.
  • For example, images from companies’ public social media accounts can generally be considered lawfully published.
  • Images from public social media accounts of public figures fall into a more ambiguous area. So far, there is no legal precedent addressing the right to cite such images in theses or scientific research.
  • Images from private individuals’ private social media accounts cannot be cited. In such cases, copyright issues intersect with ethical and data protection considerations. In principle, when requesting consent to participate in research—or when consent serves as the basis for processing personal data—permission to use images in a thesis may also be requested at the same time as consent.

You can find more information about terms of use and copyright in this educational resource section: Rights and copyright.