Rebecca Mackin of Sheppard Mullin writes:
The European Data Protection Board and the European Data Protection Supervisor recently issued a joint opinion on the processing of personal data and the role of the European Commission within the eHealth Digital Health Service Infrastructure. As background, the eHealth Network is a network of eHealth authorities designated by the EU member states. Its main purpose is ensure the continuity of cross-border healthcare of patients as they move throughout the EU. To realize this goal, the Commission created the eHDSI, the system which enables the exchange of electronic patient data amongst member states. To clarify its role as the eHDSI creator and operator, the Commission sought the joint opinion of the EDPS and EDPS as to whether it was acting as a processor.
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