The Anonymization of Genetic Data in the European Health Data Space: Criteria of Identifiability and the Scope of the Prohibition on Re-identification Following the CJEU Judgment of 4 September 2025

Abstract

The secondary use of genetic data within the European Health Data Space raises specific challenges regarding anonymization and pseudonymization. Since genetic identity resides in the statistical combination of multiple genetic variations, an effective anonymization strategy should enable data access bodies to address the criteria of singling-out, linkability, and inference, as well as all reasonable means of re-identification.