Genetic data has played an important role in health research in the development of a vaccine against COVID-19. On 1 July, 2020, Bavaria (a state in Germany) began providing free COVID-19 tests for all residents in an attempt to control, monitor, mitigate, and detect the virus.[1] However, this raises concerns over whether there may be a secondary research purpose. The DNA data could potentially be re-used by the government as well as private entities to develop a vaccine without the consent of the data subjects. DNA sequencing help researcher to identify different strain of viruses to assist in vaccine development. Nevertheless, it is unclear whether there is any legitimate basis for the genetic data to be processed for secondary purposes, albeit in the public’s interest, without the consent of the participants. This paper discusses to what extent, under the General Data Protection Regulation (GDPR), can organisations process genetic data for health research in terms of vaccine development?

[1] THE LOCAL de “Free coronavirus tests for everyone in Bavaria” [2020] < https://www.thelocal.de/20200701/free-coronavirus-tests-for-everyone-in-bavaria-what-you-need-to-know> [accessed on 31 October 2020]. And see also COVID-19 Testing Policies, 31 October 2020 at < https://ourworldindata.org/grapher/covid-19-testing-policy> [accessed on 31 October 2020]. European Centre for Disease Prevention and Control “Testing strategies for SARS-CoV-2” at < https://www.ecdc.europa.eu/en/covid-19/surveillance/testing-strategies> [accessed 2 November 2020].