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Sending personal data, receiving non-personal data: Recent EU judgment reinforces the power of pseudonymization

A new EU General Court ruling has nuanced the threshold between pseudonymous and anonymous data. In particular, it clarifies that supervisory authorities need to carry out a “test” to assess whether data can be deemed...more

Public consultation on binding rules for phone marketing – Spanish update

The Spanish Data Protection Authority has opened a public consultation process to obtain comments for an incoming decision establishing the rules for commercial communications via telephone. This decision will be binding upon...more

Re-use of health data to train algorithms: European Union EDHS Proposal

The European Health Data Space Regulation (still a proposal) will bring huge changes to the handling and possibilities of electronic health records in the European Union. It will create a common environment, with...more

The reuse and transfer of data held by public sector bodies under the EU Data Governance Act

The Data Governance Act is meant to foster the creation of a single European market for data sharing and re-use to enhance its commercial and scientific potential. Data held by public sector bodies are likely to be of key...more

EU Data Act Series (part 3): medical and health devices and data sharing obligations

The Data Act Proposal envisages the rights of users of medical devices / health wearables to have access to and to share the data originated from the use of the device with third parties. These access and sharing rights are...more

European Health Data Space: a revolution for electronic health records

Health care providers (both private and public) store and make use of electronic health records ("EHRs") in the context of providing health care services. However, the configuration of such EHRs by health providers in the EU...more

Los lagos de datos ahora están regulados – Data Governance Act

En Europa, las condiciones para compartir datos entre empresas son tan complicadas en ocasiones que el potencial de la industria no está tan explotado como podría. Esto conlleva una pérdida de competitividad de la industria...more

Data pools for sharing data are now regulated – EU Data Governance Act

In Europe, the current conditions for sharing data between companies are so complicated that the potential of the industry is not fully exploited. This results in the loss of competitiveness of the European industry compared...more

Data Act: the era of data availability (Part 1: obligation to share data)

The Data Act Proposal aims to provide fairness to data access and proposes new rules on who can use and access data generated in the EU across all economic sectors. It creates the obligation for manufacturers and designers to...more

Pharmacovigilance in Spain: Takeaways from the new code of conduct (Part 2)

Some weeks ago, we described the highlights of the new "Code of Conduct on the processing of personal data in the field of clinical trials and other clinical research as well as pharmacovigilance" (CoC) and the impact on data...more

AI & Algorithms (Part 6): Spain to create Europe's first supervisory agency for artificial intelligence

The European Union is investing resources and issuing legal tools in order to foster the lawful and accountable use of artificial intelligence (AI). In Spain, the Government is also working to promote and maximize the use of...more

New possibilities for data : European Union legal developments

The EU has moved up a gear in recent times, and it is producing new legal tools for companies to maximize the possibilities to collect and make use of data (including personal data) in the context of its European Strategy for...more

Data Governance Act. Blowing away barriers to accessing data held by public entities

The European Union has already enacted several Directives to allow (or mandate) the possibility for companies to access and re-use the data held by EU public administrations in the European Union. However, in many cases this...more

Nuevo modelo tipo de contrato de encargo del tratamiento de la Comisión Europea

La Comisión Europea acaba de publicar un modelo tipo de contrato de encargo del tratamiento bajo el artículo 28 del Reglamento General de Protección de Datos ("RGPD"). ...more

Compatibility test: Can I process lawfully collected personal data for a new purpose?

When launching a project that involves processing of personal data, previously collected for a different purpose, what are the requirements? Companies usually focus on the legal basis of processing and information duties, but...more

EDPB’s New Guidelines – Clinical Trials in the EU and COVID-19

We currently live in a world where the rapid spread of COVID-19 has provoked the urge to initiate the search for an effective vaccine or medicines to fight against it....more

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