Cegedim Santé: pseudonymous health records still required the right authorisation

CNIL’s notice describes data collected through medical software and used for health-sector studies and statistics. It found that patients could be re-identified by reasonable means, so the records were not anonymous. CNIL notice published on EDPB.

The authority found missing required health-sector formalities and unlawful automatic collection of reimbursement-history data when doctors consulted the relevant service. CNIL notice published on EDPB.

CNIL imposed EUR 800,000. This record follows the authority’s notice published on EDPB; the full national decision was not reviewed. No later appeal result or payment is asserted. CNIL notice published on EDPB.

These are implementation checks suggested by Inth, not additional findings about the company.

• Map which identifiers and attribute combinations survive each export and whether records can be linked over time.
• Separate a clinician’s ability to consult information from automatic collection for a secondary purpose.
• Have the relevant privacy and clinical teams establish applicable authorisations, legal bases and re-identification controls.

Code audit can help trace reviewed data collection, storage and external destinations.

It cannot certify anonymisation or grant the health-sector authorisations considered in this decision. A browser scan cannot assess an internal health-data warehouse.

• CNIL notice published on EDPB

Source review: 19 October 2026. This is a dated account of the cited authority decision. A recorded fine is not a confirmed payment. Later procedural developments are stated only where the linked record establishes them. Inth wrote the implementation checks; they do not establish legal compliance or replace legal advice.