“A double no: to logic and substance”, in this way Alessandro Del Ninno, IT partner of Tonucci & Partners and professor of Legal Informatics at Rome LUISS Guido Carli, defines the recent Privacy Authority rejection of the decrees regarding health data ecosystem and electronic health record (ESF). The two decree frameworks, vitiated by extreme generality and indeterminacy as to fundamental aspects concerning personal data protection, were negatively commented because written “without having first outlining the decrees that design the system of the reformed Electronic Health Record and without having completely implemented the compliance indications that the Authority has provided as per its opinions expressed since 2014 “.
Moreover, the correction of a second draft decree was also requested in order to encourage and improve the implementation of ESF at a national level.