ILN Data Privacy Paper

Portugal

As referred, personal data is defined in Article 4(1) of the GDPR and consists of any information relating to an identified or identifiable person On the other hand, non-personal data refers to data that does not relate to an identified or identifiable natural person: in other words, anonymous data or data that has been subsequently anonymized and cannot be attributed or used to identify in any way a specific individual/natural person. It should be noted, however, that mixed records often contain both personal and non-personal data (i.e., company tax records that include the name and telephone number of the company's director). In most cases, the personal and non- personal data in mixed data sets are

inseparable, and if it is a mixed data set, it must therefore comply with the rules of the GDPR and the PDPL. Ø Regulation of electronic and non- electronic data In Portugal, electronic and non- electronic data are primarily regulated by the GDPR and the PDPL, which establish rules for the processing of personal data, regardless of the format in which it is stored. In the field of health and genetic data processing, Article 29(2) PDPL establishes that in the cases provided for in Article 9(2)(h) and (i) of the GDPR, the processing of the data provided for in Article 9(1) of the GDPR must be carried out by a professional bound by secrecy or by

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