Global public health security

Global public health security is defined by the World Health Organization as the activities required, both proactive and reactive, to minimise the danger and impact of acute public health events that endanger people's health across geographical regions and international boundaries. It encompasses surveillance, early warning, laboratory capacity, outbreak response, vaccine and medical countermeasure development, and the coordination mechanisms established by the WHO International Health Regulations (2005) and, in the EU, Regulation (EU) 2022/2371 on serious cross-border threats to health and the mandate of the Health Emergency Preparedness and Response Authority (HERA).

The COVID-19 pandemic demonstrated how closely health security depends on data: case reporting, contact tracing, genomic surveillance of pathogens, vaccine pharmacovigilance, and rapid platform trials all required cross-border sharing of health data at unprecedented scale and speed.

The GDPR anticipates this: Art. 9(2)(i) permits processing of special category data for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, on the basis of Union or Member State law providing suitable safeguards, and Art. 49(1)(d) allows international transfers for important reasons of public interest. The EDPB statements of 2020 on the pandemic stressed that these bases do not suspend the principles of minimisation, storage limitation and transparency. Sponsors developing vaccines and countermeasures should therefore document the public-interest basis, the national law relied on and the safeguards applied, rather than assuming that an emergency dispenses with them.