The German Conference of Independent Supervisory Authorities (“DSK”) published on March 23, 2022 a statement on scientific research and data protection (see here, in German).  The DSK published the statement in response to the German Government’s initiative on a general law on research data as part of its Open Data Strategy, announced on July 6, 2021.  The DSK also refers to the Government’s intention to introduce a law on the use of health data, including the storage of data in electronic health records.

According to the DSK, the GDPR aims to strike a balance between, on the one hand, freedom of research and, on the other hand, the right to data protection.  In particular in relation to the purpose limitation principle, the DSK recognizes that the GDPR reflects a political choice of the EU to foster scientific advancements and strengthen the Union’s economic and technological foundations, to create a European science area.

The DSK emphasizes the importance of the GDPR’s principle of data minimization in scientific research.  It provides that entities performing scientific research should rely as much as possible on de-identification methods such as anonymization, pseudonymization, and data custodianship.

Finally, the DSK announced that it will be providing “constructive advice” on national and EU legislative developments that aim to create an open health data space, including by publishing statements or papers in the “near future”.