健康医疗数据个人信息保护的欧盟经验与中国启示OA

In the context of global healthcare digital transformation,the utilization and protection of healthcare data face challenges.China's Personal Information Protection Law still exhibits structural flaws,such as lagging anonymization standards and a lack of secondary utilization mechanisms.The European Union has established a dynamically balanced governance framework through the General Data Protection Regulation and the European Health Data Space Regulation.The core of this framework lies in creating a tiered governance model for"primary use"and"secondary use",and establishing a health data access authority to implement centralized supervision,providing a model for rights protection and data benefit release.Drawing on the EU's experience,China should improve in three aspects:formulating specialized legislation for healthcare data,distinguishing between utilization scenarios;establishing a unified regulatory authority;introducing dynamic anonymization assessment and a data subject objection mechanism,ultimately constructing a new governance framework that balances protection and utiliza-tion.