Data stored in the secure DHSC IT infrastructure does not contain direct, indirect or consistent identifiers. This means that the storage of this data should not be considered in the legal context of the RGPD/data protection. However, limits must be set for the retention of data sets and datasets, even if the data is not personal data. This applies to the analytical data described above. On 15 July, the European Commission announced that it had adopted an implementation decision to facilitate a voluntary gateway service to ensure the interoperability of contact tracking and alert applications across the EU as part of the fight against Covid-19. The decision establishes rules under which the European Commission acts as a provider of technical and organisational solutions for the gateway and deals with personal data pseudonymised on behalf of EU governments. This gateway should allow citizens, especially those travelling in the EU, to install a single application instead of downloading a separate application for each country. This decision is based on interoperability guidelines and technical specifications agreed between Member States and the European Commission (which we reported in our May and June updates). 6. Do we need to share contact information with others? NOYB`s judicial review could be a sign of further challenges ahead against the Irish CPD, which is under increasing pressure to deal with data protection complaints against many large technology companies that have moved their EU headquarters to Ireland. Any use of the data and information generated or collected by the application complies with data protection legislation and the common law duty of confidentiality (if any). Italy`s data protection authority recently imposed two major fines.

The first was adopted on 10 June 2020 against UniCredit Bank for violating the Italian Data Protection Code (Italian Data Protection Act before the RGPD). Guarantor found that between April 2016 and July 2017, the external counterparty illegally accessed the personal data of more than 700, 000 UniCredit customers. This is the result of UniCredit`s inability to implement appropriate security measures. The imposition of the fine of 600, 000 euros revealed UniCredit`s voluntary self-declaration after discovering the data failure. We work more closely with health care (doctors, hospitals, etc.), with health and social services growing. The government says we need to share your NHS number. If we work with our health partners on things like the Better Care Together program, we will try to do so if possible with your agreement. Social workers share data with health care professionals as part of your direct care care team. Sometimes we have to share without telling you for legal reasons, or if it is in your vital interest. We must also comply with the NHS Data Security and Protection Toolkit, which sets strict standards for the use of your data.

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