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To protect the data privacy of individuals, various legislative instruments prescribed the anonymization or pseudo-anonymization of data before such data may be shared for purposes including health research. However, the mere mention of this requirement is not sufficient. Considering the rapid development in both anonymization techniques, including re-identification attacks and the ease with which they can be implemented as a result of data aggregation, it is important to find consensus about the meaning of anonymization and, most importantly what techniques are considered to be sufficient to achieve true anonymization for purposes of data sharing and secondary use of data as advocated for in the European Health Data Space proposal. In this paper, we investigate the current state of the terminology used and how it is approached in different legal instruments and then consider this against the aims and goals of the European Health Data Space proposal. Lastly, we shall consider the available and potential techniques that may be valuable in anonymizing data for purposes as contemplated in the European Health Data Space proposal.

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Techniques to Achieve Anonymization of Health Data: When are They Sufficient to Be Considered as Legally Complaint?

  • 会议论文

  • 发表日期：

    2025年

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  • Fatma Sumeyra Dogan,
  • Soumia Zohra El Mestari,
  • Marietjie Botes

摘要

To protect the data privacy of individuals, various legislative instruments prescribed the anonymization or pseudo-anonymization of data before such data may be shared for purposes including health research. However, the mere mention of this requirement is not sufficient. Considering the rapid development in both anonymization techniques, including re-identification attacks and the ease with which they can be implemented as a result of data aggregation, it is important to find consensus about the meaning of anonymization and, most importantly what techniques are considered to be sufficient to achieve true anonymization for purposes of data sharing and secondary use of data as advocated for in the European Health Data Space proposal. In this paper, we investigate the current state of the terminology used and how it is approached in different legal instruments and then consider this against the aims and goals of the European Health Data Space proposal. Lastly, we shall consider the available and potential techniques that may be valuable in anonymizing data for purposes as contemplated in the European Health Data Space proposal.