Guidelines 03/2020 on the processing of data concerning health for the purpose of scientific research in the context of the COVID-19 outbreak

Section 5.1  Transparency and information to data subjects

29. The principle of transparency means that personal data shall be processed fairly and in a transparent manner in relation to the data subject. This principle is strongly connected with the information obligations pursuant to Article 13 or Article 14 GDPR.

30. In general, a data subject must be individually informed of the existence of the processing operation and that personal (health) data is being processed for scientific purposes. The information delivered should contain all the elements stated in Article 13 or Article14 GDPR.

31. It has to be noted that researchers often process health data that they have not obtained directly from the data subject, for instance using data from patient records or data from patients in other countries. Therefore, Article 14 GDPR, which covers information obligations where personal data is not collected directly from the data subject, will be the focus of this section.