A new giant nominative computer file is likely to identify your personal data. The government of Jean Castex created the device “SI Vaccin Covid” by a decree published Saturday December 26 at Official newspaper, on the eve of the launch of the French vaccination campaign against Covid-19.
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The objectives of the file
This processing, for which the Directorate General of Health (DGS) and the National Health Insurance Fund (Cnam) are responsible, serves several purposes, such as:
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- the organization of vaccination of eligible persons;
- monitoring the supply of vaccines and consumables to vaccination sites (syringes, compresses, disinfectants, etc.);
- the sending to the vaccinated person of a summary of information relating to the vaccination, drawn up by the health professional carrying out the vaccination or by the staff placed under his responsibility;
- pharmacovigilance (monitoring vaccines and preventing the risk of adverse effects);
- statistical monitoring of the campaign;
- carrying out studies and research.
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A new risk linked to anti-Covid vaccination appears? The file must allow the transmission to people of information on this risk to vaccinated people and, if necessary, their referral to an appropriate course of care.
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The information present in the file
The computer processing mentions in particular the elements of identification concerning the person invited to be vaccinated or vaccinated (name, first names, sex, date of birth, place of birth, social security number or admission code for the benefit of thestate medical aid, AME). It also includes the contact details of the person and their possible legal representative (postal address, telephone number, e-mail address).
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In addition, the file contains a series of information on vaccination:
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- the references of the voucher and / or vaccination vouchers issued to the person;
- data relating to the completion of the vaccination (dates of the injection (s), information allowing the identification of the vaccine injected, details on the administration of the vaccine, identification of the site (s) of vaccination, identification of the health professionals who carried out respectively consultation prior to vaccination and each injection).
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Personal health data is stored in the system:
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- medical eligibility criteria and treatments followed;
- information relating to research and identification of contraindications to vaccination;
- possible side effects associated with vaccination.
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Information on the non-medical eligibility criteria for vaccination (for example, residence in an accommodation facility for dependent elderly people, nursing home) is present in the file. Finally, it also mentions the identification data of health professionals and persons placed under their responsibility who have carried out the prior consultation and vaccination.
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Health professionals and persons under their responsibility who assist with vaccination must “Record the data collected without delay”.
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Data recipients
Only certain people and organizations may have access to all or part of the processing data, for public health purposes. These include:
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- health professionals and persons placed under their responsibility carrying out the prior consultation and vaccination;
- the attending physician;
- of the CNAM;
- of the National Agency for Medicines and Health Products Safety (ANSM).
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The data makes “Subject to adequate pseudonymization measures” for certain recipient individuals, such as:
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- persons authorized by the Director General of Public Health France;
- those authorized by the directors general of the regional health agencies (ARS).
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A right of access and rectification
The vaccinated people can obtain access and rectification of the data concerning them in the file. However, they cannot obtain their erasure. The right to oppose the registration of their data in the device is very limited.
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The vigilance of the Cnil
The National Commission for Informatics and Freedoms (Cnil) had, in an opinion of December 10 published in the Official Journal of the 26, issued criticisms concerning the draft decree. She had concluded by warning “That it will be vigilant as to the conditions of implementation of the file and that it will exercise its power of control”.
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