FinlandAct on the Secondary Use of Health and Social Data, Pseudonymisation and Anonymisation of Permitted Data (Sections 14, 15, 51, 51 d and 52)
Laki sosiaali- ja terveystietojen toissijaisesta käytöstä 552/2019, 14, 15, 51 and 52 §
In force since .
A de-identification rule binding public and private bodies.
- Obligation class
- Governance, Security
- Audit expectation
- none
What it requires
- If you are the permit authority or an organisation named in section 6 that has granted a data permit or made a positive data request decision, pseudonymise or anonymise the data set before the permit holder processes it, or produce the aggregated statistical data the request asks for (section 14).
- If you are the permit authority or an organisation named in section 6, keep a description of how you formed each data set and aggregated statistic you released, of the pseudonymisation and anonymisation methods you used and of the results you released (section 14).
- If you release personal data as pseudonymised data under several different data utilisation plans, pseudonymise it with a different identifier for each release (section 14).
- If you are the authority that granted a data permit on pseudonymised data, keep the identifiers securely, so that the data set can be made identifiable again and reproduced, for as long as the research and the checking of its results need them (section 15).
- If you hold a data permit and want to bring results out of the secure processing environment, anonymise them, tell the permit authority that you intend to bring them out, and expect the permit authority to verify the anonymisation on a risk-based assessment (section 52).
These lines are LexLint's reading of the law's text.
Who enforces it
Enforcement body
The Social and Health Data Permit Authority (Sosiaali- ja terveysalan tietolupaviranomainen) supervises compliance with the conditions of the permits it grants and may revoke a permit if the permit holder does not comply with the Act or breaks the permit conditions (section 5).
What record it asks for
What the log must hold
Data lineage
Logging duty
Section 14 requires the permit authority and the organisations named in section 6 to keep a description of how they formed the data sets and aggregated statistics they released, of the pseudonymisation and anonymisation methods they used and of the results they released. It states no duty to log individual access or processing events; section 15 separately requires the identifiers of pseudonymised data sets to be kept.
- Kind
- Explicit
- As of
- Provision
- Section 14, paragraph 1
- Trigger
- personal_data_processing
What this law does
Section 14 provides that, once a data permit or a positive data request decision has been granted, the permit authority or the organisation that granted it compiles, combines where needed and pre-processes the data and pseudonymises or anonymises the data set for the permit holder to process, or produces the aggregated statistical data the request asks for.
Section 14 requires the permit authority and the organisations named in section 6 to keep a description of how they formed the data sets and aggregated statistics they released, of the pseudonymisation and anonymisation methods they used and of the results they released. Section 14 requires personal data released as pseudonymised data under several different data utilisation plans to be pseudonymised with a different identifier for each release.
Section 15 requires the authority that granted the permit to keep the identifiers of pseudonymised data sets securely, so that a data set can be made identifiable again and reproduced, for as long as the research and the checking of its results need them. Section 51 d allows an organisation named in section 6 to grant, for a special reason, a permit for data in anonymised form outside the secure processing environment where the application concerns only that organisation's data.
Section 52 requires a permit holder who wants to bring results out of the secure processing environment to anonymise those results. Section 52 requires a permit holder who anonymised the results to tell the permit authority that it intends to bring them out, and has the permit authority verify the anonymisation on a risk-based assessment.
When LexLint raises it
When your app profile says your app handles health records or processes de-identified data.
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