17.03.2016

Transfer of key-coded research data under the planned EU-US-Privacy Shield

Just for my personal digital memory, excerpt from Annex II to the draft Adequacy decision (emphasis added):
Key-coded Data
i. Invariably, research data are uniquely key-coded at their origin by the principal investigator so as not to reveal the identity of individual data subjects. Pharmaceutical companies sponsoring such research do not receive the key. The unique key code is held only by the researcher, so that he or she can identify the research subject under special circumstances (e.g., if follow-up medical attention is required). A transfer from the EU to the United States of data coded in this way would not constitute a transfer of personal data that would be subject to the Privacy Shield Principles.