How is ‘ removal’ defined? In my thinking, it means the right to have data labelled such that is NOT used in the provision of healthcare.
Copies made in the past, can not easily be removed, all the times. Data shared with third parties can not easily be removed. Data that is acted upon, can not easily be removed. Data that is re-used for administrative purposes or legal reporting can not easily be removed. Think of use of data in legal proceedings, used for administrative purposes, data logged in the log-file. The law and its regulations (based on EU law) can write what they like. Reality, technology, choices made in the past, will never change in the sense that all data can physically be removed. At best it is removed logically and locally, meaning it is not allowed to play a role in the provision of healthcare in the future. That is and stays my opinion. GF Gerard Freriks +31 620347088 gf...@luna.nl Kattensingel 20 2801 CA Gouda the Netherlands > On 7 Nov 2017, at 18:15, Bert Verhees <bert.verh...@rosa.nl> wrote: > > I just received ab email about this. In Dutch from the Dutch Authority > Privacy (Autoriteit Persoonsgegevens ) > > The DPIA mentions very explicitly right on correction and right on removal. > Else the system owner will be fined. It is European law. > > No room for discussions or ethical considerations. Just law. The KNMG, Royal > Dutch Society for Medical Affairs states the same. > > They do not say logical or physical removal, they just say removal. If I was > responsible. I would know how to be sure to do the right thing. I guess > everybody else also knows what to do. > >
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