EBA DPO/Privacy Officers Group Paper – GDPR
The EBA DPO/Privacy working group was formed in early 2018 in response to the new Europe wide data protection legislation the General Data Protection Regulation (GDPR) EU 679/2016 coming into force in May of that year. One of the aims of the group is to conduct research, provide opinions, guidance and ultimately position papers in relation to data protection topics insofar as they apply in relation to blood transfusion.
The specific purpose of this paper relates to the right to be forgotten, it aims to provide guidance on how to interpret this right under data protection legislation in the blood transfusion context. Specifically the paper relates to blood components, tissues and cells, including from cord blood and bone marrow. While organs are outside the remit of the group and the EBA, it is acknowledged that there are many points of similarity both in terms of the governing legislation and its objectives, for example traceability. Much of the guidance provided here could therefore be of some use in that context also.
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