Data

CPME Rapporteur: dr. Sjaak NOUWT (NL) 
CPME Secretariat: Ms Sara RODA

Personal data protection

CPME believes that a high level protection of all citizens’ data is essential, in particular health and medical data. As the patient-doctor relationship is built on confidence and trust, medical records should be considered as particularly sensitive data. At the same time, it is of utmost importance that healthcare data be stored with the appropriate security standards, for purposes of proof of medical treatment and for future patient’s safety. Following the adoption of the General Data Protection Regulation (GDPR) on 27 April 2016, CPME closely monitors the implementation of this regulatory framework, as well as related legislation with impact to the processing of data concerning health, patient confidentiality and professional secrecy.

Data management

In February 2020, the European Commission published a ‘European strategy for data’ whose ambition is to enable the EU to become the most attractive, secure and dynamic data-agile economy in the world. The strategy aimed at developing common European data spaces in strategic economic sectors and domains of public interest, such as the common European Health Data Space (EHDS). The proposal for a regulation on the EHDS was published in May 2022 and the provisional political agreement reached in March 2024. CPME closely monitored and contributed to the debate, making sure physicians’ views were taken into account.

Key messages:

  • Easier access to individual’s data, specifically patients’ data, needs to be surrounded by strong legal safeguards and level of security. 

  • Patient confidentiality and professional secrecy must be preserved online and offline.

  • To foster trust in the sharing of health data, there should be the involvement of research ethics committees or ethics review boards when the legal base to share personal data is other than consent of the data subject.

  • The default position for provision of information should be anonymisation, which should be irreversible and legally guaranteed.

  • Pseudonymisation, if necessary, can be only in accordance with the national medical practitioner regulator.

Featured Policies

Feb 2024 CPME 2024/005 FINAL
Reaction to Council’s Mandate and European Parliament’s Amendments on European Health Data Space
CPME statement highlighting key aspects for the trilogue negotiations on the European Health Data Space (EHDS), to ensure a positive impact for healthcare.
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Other Policies

Dec 2023 CPME 2023/141 FINAL
Joint Letter CPME, CED, EFN and PGEU
Call to Action and Plenary Amendments for European Health Data Space
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Nov 2022 CPME 2022/065 FINAL
CPME Position on the European Health Data Space
The position raises concerns about medical ethics, the burden on doctors and the national competence of Member States.
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Jul 2022 CPME 2022/077 FINAL
CPME Feedback on European Health Data Space Proposal
The response highlights the cultural shift on health data sharing, the high impact for European Doctors and small practices, in particular in relation to the primary use of health data. It comments among other on the importance of consent and research ethics committees, as well as on the need for a differentiated approach for the data categories in secondary use.
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Jun 2022 CPME 2022/023 FINAL
Challenges of Health Data in Europe - Are we preparing?
Report of the event co-organised by the Conseil National de l’Ordre des Médecins (CNOM) and the Standing Committee of European Doctors (CPME) within the context of the French Presidency of the Council of the European Union, to discuss and address the benefits and challenges of the digital transformation in healthcare in Europe.
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Apr 2022 CPME 2022/056 FINAL
CPME Flyer: Role Ethics Committees in EHDS
Research opportunities using ‘big data’ cannot result in weakening of applicable ethical standards. There should be the involvement of research ethics committees or ethics review boards when the legal base to share personal data is other than consent of the data subject.
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Mar 2021 CPME 2021/097 FINAL
CPME Policy on European Health Data Space - Focus on Health Research and Policy Making
Sharing patient data needs to go along with strong legal safeguards and security. Governance structures and transparency are essential to supervise the use and re-use of data. To foster trust in the sharing, there should be the involvement of research ethics committees when the legal base to share patient data is other than consent of the data subject. The default position for sharing patient data for other purposes than primary care should be irreversible anonymisation, which should be legally guaranteed.
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Oct 2021 CPME 2021/116 FINAL
Joint Compendium: Demonstrating Gaps in the e-Evidence Regulation, 20 October 2021
CPME and 13 civil rights organisations cdevelop scenarios to demonstrate the disproportionate impact of the future eEvidence Regulation on the protection of sensitive health data, among other.
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