Health Data – A Question of Both Life and Privacy
From life-saving innovations in digital health to growing concerns about privacy, health data sit at the crossroads of opportunity and risk. Dr. Zhicheng He’s doctoral dissertation examines how two of the world’s major jurisdictions – the EU and China – seek to govern this delicate balance.
Imagine your smartwatch detecting early signs of heart problems, or a digital health system predicting a flu outbreak in time to slow its spread and protect those most at risk. Health data can quite literally save lives – but they are also among the most sensitive information we hold. How, then, can these data be used to generate benefits for individuals and society without undermining the right to privacy?
This question lies at the heart of Dr. Zhicheng He’s doctoral dissertation Health Data Governance in the Era of Digital Health: Legal Approaches of the EU and China, which he successfully defended at the Faculty of Law, Stockholm University, on 5 September 2025.
Data that can transform healthcare
Health data include medical records, test results and imaging scans – but also information from fitness apps, wearables, and even mobility patterns during a pandemic. During COVID-19, their importance was clear: health data enabled rapid contact tracing and played a crucial role in the development of effective vaccines.
Today, health data are being used to detect diseases earlier, tailor treatments to individual patients, and support elderly care through digital solutions. The potential is enormous – but so are the risks. Who should have access to these data? Could they be misused? And how do we ensure that privacy rights are not eroded in the process?
Between anonymisation and innovation
Zhicheng He explores how the EU and China address this delicate balance. A key question is anonymisation: can data be processed in a way that they no longer qualify as personal?
In the EU, legal practice has shifted from a strict privacy-oriented approach to a more flexible, risk-based strategy, most notably reflected in the GDPR and the new European Health Data Space (EHDS) regulation. In China, anonymisation also plays a role, but the governance model relies more on technical standards and a comparatively simpler legislative framework, with a stronger emphasis on treating data as a resource for public governance and economic development.
Privacy-enhancing technologies (PETs) emerge in both systems as vital tools – though in legal terms, they often resemble pseudonymisation rather than full anonymisation.
Two systems – different paths, common goals
Both the EU and China have enacted comprehensive data protection laws – the GDPR and the Personal Information Protection Law (PIPL) – explicitly classifying health data as sensitive information. This is a notable similarity, yet beneath the surface significant differences remain.
The EU, grounded in the protection of fundamental rights, employs a “dual-track” model that layers safeguards and emphasises individual autonomy. China, by contrast, applies a more flexible “single-track” model, giving greater weight to public interest and broader governance objectives.
These differences reflect deeper value systems: Europe places the individual at the centre, while China highlights societal needs.
A contribution to global governance
One of the most significant contributions of Zhicheng He’s dissertation is its identification of a pattern of “convergence in divergence”. Despite their differences, both the EU and China are moving towards similar institutional solutions, driven by shared global challenges: digitalisation, ageing populations, and new public health crises.
His research does more than compare two systems – it provides concrete insights for future policymaking. It shows how jurisdictions can learn from each other by reflecting on alternative solutions: the EU may draw on China’s pragmatism and flexibility, while China can benefit from Europe’s strong rights-based protections and detailed regulatory frameworks.
Ultimately, the dissertation invites us to reflect on a broader question: how can we build a future where health data are fully harnessed to promote human well-being – without paying the price in lost privacy?
Read the thesis with Open Access in DiVA
About the Public defence | September 5 | 2025
Opponent was Associate Professor Tuomas Pöysti, Helsinki University.
The examining committee consisted of Professor Björn Lundqvist, Stockholm University, Associate Professor Cyril Holm, Uppsala University, Dr. Jiahong Chen, The University of Sheffield, and Professor Annamaria Campanini, IASSW.
Supervisors was Professor Mauro Zamboni and Associate Professor Stanley Greenstein, Stockholm University, and Doktor Martin Kampel, TU Wien.
Text: Natalie Oliwsson
Last updated: September 11, 2025
Source: Department of Law