Aug 07, 2019 Actor Type Activity Version
Jose Costa-Teixeira Comment commented 11:34 AM

Where is the REQ1 in this list? ("it must be clear on which basis a processing is done and for which purpose")? We only talk about explicit consent and that is not the key thing.

Comment commented 11:33 AM

This is IMO the core requirement, REQ1 - a basis for a specific processing, including purpose and legal grounds.

Comment commented 11:31 AM

What is the meaning of this sentence? What would be a regulatory requirement? What about patient care provision which would be the most common reasons for data processing? Do you call this a regulatory requirement? There is a long path between "care provision" in the law and "sending a prescription to a pharmacy". the former could be but the latter is not a regulatory requirement. and I see no need for consent when sending a prescription.

Jul 01, 2019
Jose Costa-Teixeira Comment commented 6:14 PM

I think this is a crucial point - IMO this is not the best formulation. "regulatory requirement" sounds like one of the 6 grounds for processing. This should read "there are several reasons why data can be processed". The other columns only cover consent, so this still seems consent-centric. Besides, there should be a clear indication that consent must be free and explicit (which in many/most healthcare situations is not - in an example, if a patient gets a very clear and friendly paper to give their consent but if the hospital says "if you don't agree to share the data, you cannot be treated" this consent is clearly not valid for GDPR (my opinion) and therefore is meaningless for allowing data processing.

May 11, 2019
Kathleen Connor Comment commented 4:25 PM

Agree. Device actors are as important as those listed here for all aspects of privacy/security/provenance/trust

Alexander Henket Comment commented 10:31 AM

I'm missing "What did some action" in this list. Devices will be active actors too and could, if not configured well leak data too.

From Feb 25, 2019 to May 11, 2019
Alexander Mense and Alexander Henket Edit multiple updates from Alexander Mense and Alexander Henket Other contributors:
Giorgio Cangioli Comment commented 5:12 AM


From Jun 11, 2018 to Feb 11, 2019
David Pyke , Alexander Mense and Beth Pumo Edit multiple updates from David Pyke , Alexander Mense and Beth Pumo
Mar 14, 2018
John Moehrke Edit created the page at 2:57 PM