Medical data of children attending inter-institutional crèches - Commission

Opinion of 27 April 2009 on a notification for prior checking on the management of the medical data of children attending the inter-institutional crèches and kindergartens managed by the OIB (Case 2009-088)
On 27 April 2009, the EDPS adopted an opinion on the prior checking of the management of the medical data of children attending the inter-institutional crèches and kindergartens managed by the OIB. Given the particularly sensitive nature of the data being processed, the EDPS recommends that a specific legal basis should be put in place for the processing of data relating to health in the context of the crèches and kindergartens, and that at the very least the unambiguous consent of data subjects should be obtained to the medical monitoring of the children and the processing the data relating to their health by the medical service in the crèches and kindergartens. The EDPS also recommends that only data which is strictly necessary for the purposes of the processing operation should be collected, and therefore invites the medical service to re-evaluate whether the data collected on the medical form and during attendance at the crèches and kindergartens is proportionate. Regarding the storage of the medical files, the EDPS recommends that a storage period which is in proportionate to achieving the purposes of the processing operation should be adopted.