David Trower's slides for the Law and Ethics in e-Social Science workshop in Cologne, 23rd June, 2009

1. Anonymisation & pseudonymisation in large data sets for medical research Law and Ethics in e-Social Science Workshop, 24 June 2009

2. David Trower Chief Privacy Officer EMEA & Chair of Global Privacy Council IMS Health

15. Is physician linked prescription data personal? Article 29 Working Party, committee of all EU DP commissioners, produced guidance on definition of personal data in 2007. Example 1: Professional habits and practices Drug prescription information (e.g. drug identification number, drug name, drug strength, manufacturer, selling price, new or refill, reasons for use, reasons for no substitution order, prescriber's first and last name, phone number, etc.), whether in the form of an individual prescription or in the form of patterns discerned from a number of prescriptions, can be considered as personal data about the physician who prescribes this drug, even if the patient is anonymous. Thus, providing information about prescriptions written by identified or identifiable doctors to producers of prescription drugs constitutes a communication of personal data to third party recipients in the meaning of the Directive.

17. Any Questions?