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The Estonian Electronic Health Record – a Prototype for Data governance in the European Health Data Space?

Michael Denga, Thomas Hoffmann


The Estonian Electronic Health Record (‘EEHR’) enables patients and healthcare professionals to share and use health data for treatment and health administration, but also caters to so-called secondary uses such as scientific research and development of health products – an approach in line with the EU draft regulation for a European Health Data Space of May 2022 (‘EHDS’). However, neither in the Estonian record nor in the EHDS patients have a say in the collection or storage of their data in electronic patient registers; the same is true for data retrieval for secondary use. This is in obvious contradiction to informational self-determination, which is exacerbated by indeterminate permissions and prohibitions.

Michael Denga, LL.M. (London), Maîtr. en Droit (Paris), Deputy Professor at Martin-Luther-Universät Hallle-Wittenberg. Thomas Hoffmann, Tenured Associate Professor of Private Law at Tallinn University of Technology. For Correspondence: <>. A list of his publications is available at <>.


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