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The Minister for Health, following consultation with the Data Protection Commissioner, has enacted regulations, through a Legal Notice, to allow for the secondary processing of health data.

Secondary processing includes all those forms of processing that are not linked to the primary purpose (providing a health service) for which the data were collected and thus includes: administrative work, analysis of health records, compiling statistics, compiling evidence in medico-legal cases, investigation of health threats and other research activities.

This Legal Notice serves to clarify that such processing of personal data in the health sector would be deemed lawful. The relevant data controller would still be legally obliged to communicate the chosen legal basis for processing to the data subjects (usually via privacy policies/notices) and generally abide by all applicable data protection principles – especially the data quality principles enshrined in Article 5 of the GDPR.

The full text of the Legal Notice may be found here. 


This document does not purport to give legal, financial or tax advice. Should you require further information or legal assistance, please do not hesitate to contact