Data protection and life sciences

Personal data is at the very core of every life science business. Life sciences companies handle significant amounts of personal data and are reliant upon the collection and use of personal data, which often includes sensitive health-related data, in order to carry out key business functions. For example, conducting clinical trials on patients, collecting data on drug safety and adverse reactions in order to comply with pharmacovigilance requirements, and collecting genetic information for the development of personalised medicines all rely on the collection and processing of data relating to individual data subjects. Consequently, it is vitally important that life sciences companies understand, and are in compliance with, the strict rules that apply to the processing of personal data.

This Overview provides an introduction to the application of the data protection regimes to key areas of the life sciences under the EU General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR) and the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR) (together the ‘GDPR regimes’).

Assimilated law is the name given to retained EU law (‘REUL’) which remains in force after

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EU Pharma industry calls for greater clarification of HTA guidance and PICO exercises

The application of Joint Clinical Assessments (JCA) of medicines under Regulation (EU) 2021/2282 (EU HTA) which is initiated through a PICO framework- Population, Intervention, Comparator(s), and Outcomes - that defines the JCA scope was implemented in January 2025 for oncology medicines and advanced therapeutics. The Coordination Group on HTA (HTACG) published the 'Guidance on the scoping process' in November 2024 followed by six 'PICO simulation exercises' in February 2025. The EFPIA has issued a response to these support materials by presenting a three questions that require further clarification and recommendations for the successful implementation of the JCA process under the HTA Regulation. In particular, it cites the interplay between population and comparator is an area of concern which determines the number of PICOs required and states that 'further refinement is needed' for how PICOs are proposed, consolidated, and communicated. It highlights that the overall scoping process lacks transparency on how assessors and co-assessors formulate initial PICO proposals and suggests that a formal consultation process with health tech developers be introduced during the drafting of proposed PICOs. It questions the logic of consolidated decisions and feels the role of Member State dialogue is unclear in the guidance and PICO exercises. Finally, it cautions that if the JCA contains an overwhelming volume of data or insufficient evidence where the consolidated PICO imposes an evidence standard then this can undermine the purpose of the JCA.

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