Member

Should health data fall within the scope of Clause 70, this would mean that processing is no longer subject to the ICO’s balancing test, which could significantly dilute the protection of health data. It is also unclear how this might affect the rights of data subjects, who are patients, including the right to object to processing. We would like the Government to clarify how health data would be affected and how controllers of health data will be able to reassure patients that they have a valid justification for processing.