My prior employer took the same position. Patient IDs can be linked by someone (not the bioanalytical lab) to the patient demographics, therefore the data is only pseudonymized and not fully anonymized. Since our data centers were in Europe, every single one of our contracts had to have the GDPR language.
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Joleen White Ph.D.
AAPS 2024 Global Health Community Chair
Bioanalytical 101 Course Development
Senior Bioassay Development Lead
Gates Medical Research Institute
Cambridge MA
[email protected]Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
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Original Message:
Sent: 06-27-2024 18:59
From: Michele Gunsior
Subject: GDPR and new regulations
Thank you Jolene, for the response. Our EU consultant has shared that even subject IDs without any other identifying information may be considered personal information; which I don't think was the approach prior to regulations coming into effect.
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Michele Gunsior
Astria Therapeutics
Gaithersburg MD
The opinions expressed are my own and may not reflect those of my employer.
Original Message:
Sent: 06-24-2024 14:04
From: Joleen White
Subject: GDPR and new regulations
Even beyond GDPR, many low and middle income countries have sophisticated data privacy laws. For example, South Africa has POPIA (https://popia.co.za/) and Vietnam has recently announced law to strengthen their data privacy (https://www.aseanbriefing.com/news/vietnams-legal-framework-for-personal-data-protection-initiated/). It is fair to say that the US is lagging behind the rest of the world, and that data security is top of mind for our customers.
On a laboratory level, we are eliminating email attachments as much as possible and instead using a Gates MRI-owned Teams Channel to share presentations and draft documents. With Gates MRI control of access permissions, we can ensure that only authorized people have access. It is a little more flexible than the Sharepoint we used to use because the business owners have control of adding new individuals as opposed to centralized through IT. We also have data privacy provisions in nearly all of our contracts now. Even if the clinical trial data was fully anonymized, the business contacts with our suppliers also trigger data privacy, so we are taking a conservative approach.
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Joleen White Ph.D.
AAPS 2024 Global Health Community Chair
Bioanalytical 101 Course Development
Senior Bioassay Development Lead
Gates Medical Research Institute
Cambridge MA
[email protected]
Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
Original Message:
Sent: 06-24-2024 13:48
From: Michele Gunsior
Subject: GDPR and new regulations
Hello!
I was wondering how everyone is handling the new GDPR regulations with regards to clinical samples and associated data from the EU. It seems that even pseudonymized data is requiring a higher level of GDPR protection.
What are your companies putting into place, if anything? Or do you currently procedures covering GDPR?
Thanks!
Michele
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Michele Gunsior
Astria Therapeutics
Gaithersburg MD
The opinions expressed are my own and may not reflect those of my employer.
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