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Coronavirus Age, Sex, Demographics COVID-19

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As previously mentioned, the parties could agree that the supplier will manage the relationship with the third-party vendor. In our view, the situation is different if the customer specifically requests the supplier to use a certain standard product and/or service. The most common example is the use of public cloud services (AWS, Azure, etc) for the storage of data or the running of an entire solution. Whereas many years ago, most suppliers provided services on the basis of their own capabilities, systems and solutions, the situation today is significantly different.

The picture is, of course, much broader for businesses operating in other jurisdictions; those procuring and deploying AI systems in the EU, for example, will need to ensure that they comply with the EU AI Act as the provisions of the Act become effective. The shape of this legislation is currently unclear, and businesses will need to remain informed and react as the UK regulatory position develops. However, it likely requires a single entity to hold (and decide to delete) the keys – potentially undermining a key reason for using a distributed blockchain in the first place. That deletion can then be done systematically (as part of a retention limitation policy), or in response to a “right to be forgotten” request; or to “delete” incorrect data and “replace” it with a corrected version, after a GDPR correction request. Another option, proposed by the French Data Protection Authority, the Commission Nationale de l’Informatique et des Libertés (“CNIL”), is to use encryption technologies to make the underlying personal data practically inaccessible upon deletion of the encryption key. As a result, there are a number of key principles of the EU/UK GDPR that can be hard to reconcile, in practice, with the fundamental features of any blockchain.

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