On February 2021, the European Data Protection Board (EDPB) released the Document on response to the request from the European Commission for clarifications on the consistent application of the GDPR, focusing on health research. This document includes a list of questions and answers on data processing for health-related research, as submitted by the European Commission (DG Justice and Consumers) to the EDPB under Article 70 of the General Data Protection Regulation, to solve some misunderstandings and misinterpretations related to the application of the GDPR to the domain of scientific health research.
The main topics discussed are the legal basis, the further processing of previously collected data, the broad consent, the transparency of the processing, the safeguards and de-identification measures and the processing of special categories of data on a large scale and international cooperation. These topics will be further discussed in the guidelines that the EDPB is preparing on the processing personal data for scientific research purposes (due in 2021) to provide a more comprehensive interpretation of the various provisions in the GDPR that are relevant in this framework.
Stay tuned for further updates on this topic!