Johnson & Johnson welcomes the European Health Data Space (EHDS)[2] proposal and recognizes the importance of cost-effective industry access to health data in improving healthcare delivery. We suggest expanding the legitimate secondary uses of health data, including real-world evidence for decision-making. Ensuring fair competition and protecting the existing regime for intellectual property rights, trade secrets, and transparency obligations is crucial. Therefore, Johnson & Johnson emphasizes the need for harmonized approaches to data access requests, streamlining the process while fostering trust through federated data networks.
To facilitate implementation, Johnson & Johnson recommends revising the EHDS proposal’s definitions to ensure clarity and alignment with other relevant legislation. We believe this will create a cohesive framework for data sharing across the healthcare ecosystem within all EU countries. Cross-border data transfer is vital for scientific advances and Europe’s global competitiveness. Johnson & Johnson advocates for a framework enabling seamless and secure health data transfer while maintaining strict privacy and security standards. To address diverse stakeholder needs, the EHDS Board’s composition should include representatives from all stakeholders. Johnson & Johnson’s stance aims to innovate through health data, preserve IP property and trade secrets, safeguard privacy, and enhance the effectiveness of the EHDS.