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"In the backend, it has a small SQL database which stores no personal information: just the list of invitees and their status." This status is private medical

by mlok 5y ago

"In the backend, it has a small SQL database which stores no personal information: just the list of invitees and their status." This status is private medical information : in France (and all Europe probably) it is illegal to store these datas, unless you use specialized "health datas secure hosting". You cannot legally do it yourself this way. French Official Documents : Health Datas Hosting : https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000033862549/ https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI0000... Health Datas : https://www.cnil.fr/fr/quest-ce-ce-quune-donnee-de-sante https://www.cnil.fr/fr/quest-ce-ce-quune-donnee-de-sante

mytailorisrich 5y ago
Storing name, DOB, test date, test result in the QR code is a good solution IMHO and indeed using a database as a private organisation is fraught with problems. Name and DOB are reasonably needed to assert the person's identity. Especially in France everyone carries an ID card so people can show ID and certificate together. Safeguarding private information is important but some must be disclosed as necessary.
- seszett 5y ago
  What surprises me is that the person's address is stored there. It seems to me absolutely unnecessary, and I'm not even sure where they get it from as the address on record by Social Security is not supposed to be disclosed even to health professionals. I think this is only the address one gives freely to the vaccination/test center and which is not checked by anyone. I still can't think of any case where it would be useful in conjunction with your vaccination status.
  - mytailorisrich 5y ago
    According to the article the address is not included in the 2D-DOC QR code. I agree with you that it's not useful information for the purpose of a "health pass" used to gain access to venues and events. On the other hand, as a matter of Covid response strategy and enforcement of any restrictions (so for the authorities at large) it is very useful to know where a person that has tested positive lives.
    - seszett 5y ago
      That's right! I had read it wrong somehow. I don't find the information that is actually included to be too sensitive then. It might have been useful in this case but the French government itself is not allowed to have a general-purpose database of citizen's addresses. Even the address that the social security has for contact purposes cannot be legally used for this (and is probably unreliable anyway as people forget to update their address when moving) and I don't think many people would have been comfortable with communicating their addresses for the purposes of Covid tracking.
      - mytailorisrich 5y ago
        Of course they can collect addresses for this if they want. It's not a general-purpose database, either. One problem we're having in this pandemic is the squeamish and "can't do" attitude on about everything.
lovasoa 5y ago
I don't think the status counts as medical information. It is an indication of whether you will participate to the event or not. Not participating may mean that you didn't want to participate, or that you didn't have a valid health pass. The database doesn't allow you to make the difference between the two. Otherwise, any guest list would now be "medical information".
- mlok 5y ago
  My bad. You are right. To me "status" referred to the health status, but it is about attendance to the event : A vaccinated person might choose to not participate. Previous paragraph : "From that link, they can confirm their attendance, but only if they have a valid health pass."
- mytailorisrich 5y ago
  Positive status implies a negative test result and negative status more than strongly correlates with positive test. To me that's just semantics but in fact it is basically a medical status.
  - lovasoa 5y ago
    The list of participants to a sport competition has never been considered medical data (the CNIL even mentions that explicitly), even though it correlates with your medical status: you have not to be handicapped and to be healthy to run a marathon for instance. In our case, the correlation is even thinner: a yes in the database means that you have been EITHER tested OR vaccinated, and a no means that you either haven't answered the invitation or didn't have a health pass. In the end, I guess it would be for a judge to decide if that fits the definition of health data, but I am confident enough to leave it online.
    - mytailorisrich 5y ago
      > The list of participants to a sport competition has never been considered medical data That's obviously quite different here. > a yes in the database means that you have been EITHER tested OR vaccinated Yes, that's extremely specific and that's why I think that's medical data. In any case, my take is that this is complicated for no actual reason. I don't see the problem with the data contained in the 2D DOC QR code: Test result is needed, name and DOB is also needed. These are limited, reasonable data to share. The only thing the database does is to replace test and/or vaccine details by a single flag. In effect the only information removed is indeed whether the person has been tested or vaccinated (unless a test is needed in any case). That seems of little value to me.

by mlok 5y ago

mytailorisrich 5y ago

Storing name, DOB, test date, test result in the QR code is a good solution IMHO and indeed using a database as a private organisation is fraught with problems. Name and DOB are reasonably needed to assert the person's identity. Especially in France everyone carries an ID card so people can show ID and certificate together. Safeguarding private information is important but some must be disclosed as necessary.

seszett 5y ago
What surprises me is that the person's address is stored there. It seems to me absolutely unnecessary, and I'm not even sure where they get it from as the address on record by Social Security is not supposed to be disclosed even to health professionals. I think this is only the address one gives freely to the vaccination/test center and which is not checked by anyone. I still can't think of any case where it would be useful in conjunction with your vaccination status.
- mytailorisrich 5y ago
  According to the article the address is not included in the 2D-DOC QR code. I agree with you that it's not useful information for the purpose of a "health pass" used to gain access to venues and events. On the other hand, as a matter of Covid response strategy and enforcement of any restrictions (so for the authorities at large) it is very useful to know where a person that has tested positive lives.
  - seszett 5y ago
    That's right! I had read it wrong somehow. I don't find the information that is actually included to be too sensitive then. It might have been useful in this case but the French government itself is not allowed to have a general-purpose database of citizen's addresses. Even the address that the social security has for contact purposes cannot be legally used for this (and is probably unreliable anyway as people forget to update their address when moving) and I don't think many people would have been comfortable with communicating their addresses for the purposes of Covid tracking.
    - mytailorisrich 5y ago
      Of course they can collect addresses for this if they want. It's not a general-purpose database, either. One problem we're having in this pandemic is the squeamish and "can't do" attitude on about everything.

lovasoa 5y ago

I don't think the status counts as medical information. It is an indication of whether you will participate to the event or not. Not participating may mean that you didn't want to participate, or that you didn't have a valid health pass. The database doesn't allow you to make the difference between the two. Otherwise, any guest list would now be "medical information".

mlok 5y ago
My bad. You are right. To me "status" referred to the health status, but it is about attendance to the event : A vaccinated person might choose to not participate. Previous paragraph : "From that link, they can confirm their attendance, but only if they have a valid health pass."
mytailorisrich 5y ago
Positive status implies a negative test result and negative status more than strongly correlates with positive test. To me that's just semantics but in fact it is basically a medical status.
- lovasoa 5y ago
  The list of participants to a sport competition has never been considered medical data (the CNIL even mentions that explicitly), even though it correlates with your medical status: you have not to be handicapped and to be healthy to run a marathon for instance. In our case, the correlation is even thinner: a yes in the database means that you have been EITHER tested OR vaccinated, and a no means that you either haven't answered the invitation or didn't have a health pass. In the end, I guess it would be for a judge to decide if that fits the definition of health data, but I am confident enough to leave it online.
  - mytailorisrich 5y ago
    > The list of participants to a sport competition has never been considered medical data That's obviously quite different here. > a yes in the database means that you have been EITHER tested OR vaccinated Yes, that's extremely specific and that's why I think that's medical data. In any case, my take is that this is complicated for no actual reason. I don't see the problem with the data contained in the 2D DOC QR code: Test result is needed, name and DOB is also needed. These are limited, reasonable data to share. The only thing the database does is to replace test and/or vaccine details by a single flag. In effect the only information removed is indeed whether the person has been tested or vaccinated (unless a test is needed in any case). That seems of little value to me.