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The Research and Scholarship Entity Category relies on the legitimate interest approach.  This is supported by the Article 29 WP Opinion on Legitimate Interests documentation.  There has been some concern expressed that Legitimate Interests cannot be used for Public Authorities as in some countries universities and colleges are deemed Public Authorities, but this limitation is only related to activities that directly relate to work that directly relates to the "public" aspects of the worn undertaken by that organisation.  A student accessing a scholarly article or the typical day to day work of a researcher would not fall under the "public" aspects of the organisation.  There is a useful article detailing how this has been addressed in the UK.

Use of Legitimate Interests under 1995 Directive

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