.. with a great overview of interesting privacy articles and links – with an emphasis on Switzerland
Rosenthal, Der Vorentwurf für ein neues Datenschutzgesetz: Was er bedeutet, Jusletter v. 20.2.2017
This is excellent reading material – covers some very interesting aspects of Swiss privacy today (e.g. data subject access rights under current law)
Results of the Vernehmlassung and Botschaft of the Bundesrat
Summary of changes by David Vasella (post- vs. pre-Vernehmlassung Draft)
“The China Food and Drug Administration (“CFDA”) has issued guidelines aimed to implement China’s new Cybersecurity Law (“CSL”) in the administration of medical devices in China. This development is a clear signal that Chinese regulators intend to enhance cybersecurity protection in the healthcare sector.”
The below is from 2016.
Very interesting article from Freshfields, that shows the UK Information Commissioner (supported by the First Tier Tribunal) taking a practical approach to the anonymisation of personal data. Also, a reminder that clinical trial data might be subject to freeddom-of-informations requests in UK under some conditions.
Key points of interest incl.
“There was no evidence that a third party, alone, could identify participants. The evidence showed that identification would be possible by combining the patient data with NHS data, but this would have involved an NHS employee breaching professional, legal and ethical obligations, and having the skill and motivation to do so. This level of conjecture was considered remote. It is not ‘any conceivable means of identification’ that must be considered, but only ‘those reasonably likely to be used’. We ‘must consider whether any individual is reasonably likely to have the means and the skill to identify any participant and also whether they are reasonably likely to use those skills for that purpose’. ”
“The Information Commissioner had ordered Queen Mary University London to disclose patient data from a trial on chronic fatigue syndrome under the Freedom of Information Act. The Tribunal reviewed this decision.
QMUL ran several arguments but the one the Tribunal most struggled with was whether the data had been anonymised enough that it should no longer be considered personal data. If so, it would likely be disclosable under FOIA. If the data was not sufficiently anonymised, it would still be ‘personal data’ and would therefore have to be withheld from disclosure.
Although the Tribunal was split in its decision, the majority was in favour of upholding the Information Commissioner’s decision that the data had been adequately anonymised. QMUL was therefore ordered to disclose it.”
I’m not sure how much “moderation”, you can read in this. – Also, have a look at how they addressed their “cookie notice” on the page.