Findata has submitted its statement on the draft government proposal that would supplement Finland’s national legislation on the secondary use provisions of the European Health Data Space (EHDS) Regulation.
We support the key solutions proposed in the draft, including the inclusion of social welfare client data within the scope of the EHDS, the introduction of a centralised application and permit management system, and the alignment of dataset descriptions, information security requirements and fee regulation with the current Act on the Secondary Use of Health and Social Data.
We also support the proposal that Findata would serve as the coordinating Health Data Access Body and the national contact point for the EHDS in Finland.
“Through implementing the Secondary Use Act and participating in European cooperation, we have developed the expertise and networks needed to take on this coordinating role. However, successful implementation of the EHDS requires adequate human, financial and technical resources,” says Mervi Siltanen, Acting Director of Findata.
In our statement, we also highlight areas that require further development. For example, we consider that the management and verification of citizens’ opt-out rights should be centralised within the MyKanta service rather than handled through the permit management system. We also do not support derogations from the opt-out right.
Overall, our statement supports solutions that promote the secure, efficient and harmonised use of health data for research, innovation, public sector steering and decision-making, while facilitating the effective implementation of the EHDS Regulation in Finland.
