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Bridging Nordic Data

A legal overview of possibilities and obstacles for secondary use of health data for innovation and development.
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On assignment from Nordic Innovation, Deloitte Legal has carried out this legal overview of possibilities and obstacles for secondary use of health data for innovation and development.

This report seeks to identify and assess the most relevant legal obstacles likely to hinder innovation and development activities across the Nordic region, as well as to provide an overview of legal barriers that the Nordic region must address jointly. Furthermore, existing possibilities for utilization of health data for innovation and development are identified with the objective of facilitating the flow of data across the region.

In addition to being a thorough source of information for Nordic Innovation and our partners, we hope the report will encourage decision makers, businesses and relevant actors in the health and welfare sector to take an active role in further exploring the possibilities for sharing and using health data in the Nordic region.

Main findings

The consensus amongst market actors in the health sector is that health data is of great value for future research, innovation and development. However, access to health data can be problematic.

The Nordic region is known for having similar legislative framework, shared values and a long tradition for governmental co-operation. Across the Nordic region, health data is regarded sensitive of nature it is protected by strict professional secrecy. Therefore, access by disregarding professional secrecy is dependent on a legal basis. The picture is further complicated as provisions disregarding professional secrecy not necessarily are considered legal basis for subsequent processing of data under the GDPR.

Specific challenges must be addressed to facilitate for innovation and development across the Nordic region:

  • The first and most significant action point is to explicitly address innovation and development in established legislation because it will contribute to a clearer picture of when access and processing is permitted for innovation and development purposes, as well as avoid the assessment of any differences between research and development, which up until now has been a source of inconvenience.
  • Subsequently, establishment of centralized systems, standardized procedures and both regulatory sandboxes and data sandboxes for health data will presumably contribute to increased and seamless transfers of health data across the Nordic region.


Nordic Health, Demography and Quality of Life is one of the main focus areas at Nordic Innovation and is based on the priorities of the Nordic ministers of business.

With the Health, Demography and Quality of Life program, we connect people, data and innovation for a better life – and help make the Nordics the most sustainable and integrated health region in the world, providing the best possible personalized health care for all its citizens.

With this program we hope to:

  1. Help the Nordic region become a global test region and role model for sharing health data.
  2. Establish collaboration platforms and connections between local ecosystems in the Nordics and potentially interesting global marked to increase Nordic export and competitiveness.
  3. Contribute to develop better and more efficient health systems and increase health and welfare in the Nordic region.

We believe that the use and exploitation of health data will play a crucial role in our journey towards a more sustainable healthcare that will benefit Nordic citizens and businesses. We hope this report can bring us one step closer.

We have a unique possibility to become a global role model for sharing health data to benefit both citizens and businesses – let us make the most of it.


Rasmus Malmborg - Senior Innovation Adviser

Rasmus Malmborg

Senior Innovation Adviser
Rasmus has extensive international experience in complex project management, predominantly within health care system development. Prior to joining Nordic Innovation, Rasmus has been with LHL International for nine years and worked the last four years as CEO.

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