To What Extent Does the EU General Data Protection Regulation (GDPR) Apply to Citizen Scientist-led Health Research with Mobile Devices?

Abstract

In this article, we consider the possible application of the European General Data Protection Regulation (GDPR) to “citizen scientist”-led health research with mobile devices. We argue that the GDPR likely does cover this activity, depending on the specific context and the territorial scope. Remaining open questions that result from our analysis lead us to call for a lex specialis that would provide greater clarity and certainty regarding the processing of health data for research purposes, including by these non-traditional researchers.

Keywords: citizen science, data protection, General Data Protection Regulation, health research, mobile devices