Insurance Europe has published its response to a consultation by the European Commission on an EU Health Data Space (EHDS), which would aim to establish a European framework on the access and exchange of personal health data.
Such a framework should aim to establish a set of EU rules that benefit consumers and ensure a true level playing field between the organisations sharing and accessing data.
Individuals should be able to allow access to their personal data to a much higher extent than is possible today. There should, for example, be practical solutions that would allow individuals to exercise control over their data, while ensuring the security of sensitive data.
Furthermore, individuals should be able to grant other parties, such as insurers, access to the data generated by them in the course of medical treatment. For example, the conclusion and the execution of insurance contracts (eg for life, health, liability and accident insurance) can require patients to disclose relevant health data and provide verifying documents. Gathering that information often proves cumbersome and slow. These issues could be addressed if, for example, patients could instead allow the insurer to collect the necessary data from electronic health records. Additionally, the sharing of administrative data in a digital format has the potential to further optimise the reimbursement of healthcare costs by insurers.
It should also be taken into consideration that many rights, such as the right to access one’s data and the right to request its transmission in electronic format, are already guaranteed by the General Data Protection Regulation (GDPR). The regulatory proposal for the EHDS therefore should avoid any duplication of rules.