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International: GPA publishes statement on sharing of health data for travel requirements during COVID-19 pandemic

The Global Privacy Assembly ('GPA') published, on 31 March 2021, a joint statement on the importance of Privacy by Design in the sharing of health data for domestic or international travel requirements during the COVID-19 pandemic. In particular, the GPA outlined that its members had advised governments, private enterprises, charities, and non-governmental organisations on the design and development of systems that allow the processing of personal health data in a manner that best protects privacy. In addition, the GPA noted that the statement seeks to complement efforts made at a national or regional level and contribute to a positive, co-ordinated privacy outcome internationally, reflecting common global principles of data protection and privacy, including Privacy by Design and Default.

Moreover, the GPA Executive Committee urged governments, and other organisations responsible for processing health data for the purposes of international travel, to consider and pay due regard to the following principles, which among others reflect common global data protection principles and practice:

  • the processing of health data as a prerequisite of international travel may be justifiable on the grounds of protecting public health, but considering privacy risks at the outset is vital;
  • Privacy by Design and Default principles should be embedded into the design of any system, app, or data sharing arrangements regarding the processing of health data for the purposes of international travel;
  • organisations should collect the minimum health information from individuals or other sources that is necessary for their contribution to protection of public health; and
  • the cybersecurity risk of any digital systems or apps must be fully assessed, taking full account of the risks that can emerge from different actors in a global threat context.

Finally, the GPA highlight that the schemes should also be reviewed periodically to ensure that the processing remains necessary and proportionate whilst the pandemic is ongoing.

You can read the press release here.