Comments to the European Commission on Health Data Spaces

In its Communication on a European Strategy for Data, the European Commission outlines its plans to create a common European Health Data Space (EHDS). The EHDS aims to unlock the value of data for public health, treatment, research, and innovation. To achieve this outcome, it aims to foster primary uses of health data to directly support health care delivery for individuals, as well as secondary uses of health data, such as for medical research and health policymaking purposes. The roadmap identifies three pillars for the EHDS: (i) a system of data governance and rules for data exchange; (ii) data quality; and (iii) infrastructure and interoperability. The Commission will remove barriers to intra-EU trade by promoting data-sharing and interoperability across the member states while safeguarding and reinforcing data protection rights through transparency and portability.

ITIF's Center for Data Innovation welcomes the goals of the EHDS initiative and agrees that adopting measures to enable better data exchange will facilitate artificial intelligence (AI)-enabled healthcare applications in the EU and allow firms to pursue economies of scale across EU markets. Our feedback stresses the need to (i) avoid market fragmentation of the Digital Single Market, (ii) ensure data interoperability, and (iii) support the development of AI-enabled healthcare applications.