Health data

France: New guidance for data retention

By Denise Lebeau-Marianna – Partner and  Yaël Hirsch – Senior Associate The French Supervisory Authority (the “CNIL”) has issued new updated guidelines on data retention during the month of July (the “CNIL’s Guidelines”)[1]. They provide more practical guidance and update the CNIL previous Recommendations dated 11 October 2005 on the conditions of archiving personal data[2]. …

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The Netherlands: DPA changes position – taking temperature might not be subject to GDPR

Since the COVID-19 outbreak, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, “Dutch DPA”) had made it clear, on several occasions, that taking temperature tests (or otherwise processing health data) as a precautionary measure in light of COVID-19 is a strict “no go”. The position of the Dutch DPA was that most individuals, in particular employees …

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The Netherlands: Health sector once again on the radar of DPA

The Dutch Data Protection Authority (Autoriteit Persoonsgegevens,  “Dutch DPA“) previously stated that it shall focus its enforcement actions on the public and health sector, and seems to act upon its words. Just a few months after the Dutch DPA inspected more than 100 hospitals and health insurers on whether they comply with the obligation to …

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FRANCE: The new Health Information Institute in France

In France, the Health Information Institute (‘INDS’) has begun to accept requests for authorisation to access the new National Health Data System (‘SNDS’), as part of measures brought in by Act No. 2016-41 of 26 January 2016 (the ‘Reform Law’). Carol Umhoefer (DLA Piper Partner, Miami) and Jeanne Bossi Malafosse, Partner at Delsol Avocats, assess the …

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