With its European Health Data Space (EEDS), the European Union (EU) faces a major challenge: how to harness the scientific and economic value of health data while ensuring the security of the infrastructure that hosts it and its alignment with European interests and values?
The French experience with the Health Data Hub (HDH) shows that health data governance is no longer limited to privacy protection or cybersecurity. It also involves infrastructure, sovereignty, and democratic oversight.
As the EEDS moves from legislation to implementation, the EU will have to decide whether digital sovereignty is merely a political ambition or a principle that truly shapes its digital future.
The Potential of Health Data
Health data is increasingly recognized as a strategic resource for health care systems, research institutions, and policymakers.
Their large-scale analysis yields insights that improve disease prevention, promote more effective treatments, and strengthen public health decision-making.
Access to large datasets is also playing an increasingly important role in the development of artificial intelligence applications, which rely onlarge volumes of high-quality data to identify trends, improve diagnoses, and support personalized medicine.
The potential benefits extend beyond scientific research. Health data can help governments anticipate public health risks, evaluate health policies, and allocate resources more effectively. The COVID-19 pandemic has demonstrated the importance of rapid access to health information for monitoring outbreaks and guiding public health responses.
As the value of health data becomes increasingly recognized, governments are increasingly seeking to facilitate its use while protecting privacy and maintaining public trust. Since health information is among the most sensitive categories of personal data, issues of governance, security, and accountability have become central to discussions about data-sharing initiatives.
The challenge lies not only in harnessing the benefits of health data, but also in ensuring that the systems that manage this data remain reliable and serve the public interest.
The Health Data Hub and the Debate on Sovereignty
Launched in France in 2019, the Health Data Hub was designed to centralize access to health data for research, innovation, and public policy purposes. This initiative aimed to address a persistent problem: the fragmentation of health information across hospitals, health insurance providers, laboratories, insurance companies, and public institutions, which limited large-scale research and data-driven decision-making.
The platform allows authorized researchers and public institutions to access and analyze health datasets within a regulated framework. The data is pseudonymized before use (to prevent patient re-identification), and access requests are subject to review procedures. The goal is to facilitate medical research, epidemiological surveillance, and innovation in the health sector, while ensuring privacy protection.
To rapidly deploy the platform, the French government initially chose Microsoft Azure as its cloud service provider. This decision immediately sparked controversy. Critics argued that hosting sensitive health data with a U.S. company could expose European citizens’ information to requests for access under U.S. law, particularly the Clarifying Lawful Overseas Use of Data Act (known as the CLOUD Act). Concerns intensified following the 2020 Schrems II ruling on the framework governing data transfers to the United States, which raised questions about the protection of European data processed by U.S. companies.
The controversy was not limited to the location of the servers. Cloud service providers manage critical infrastructure, including storage, encryption, computing environments, and access controls. Although the Health Data Hub’s data is hosted in Europe, critics argued that reliance on a non-European provider created legal and strategic vulnerabilities that technical measures alone could not eliminate.
The debate quickly became a symbol of a broader European concern: Should strategic digital infrastructure remain dependent on foreign technology providers?
To address this concern, France announced in late April 2026 that the Health Data Hub would be migrating to the French cloud service provider Scaleway.
From the Health Data Hub to the European Health Data Space
The European Health Data Space (EEDS) aims to extend the concept of the Health Data Hub (HDH) to the entire European Union. Its goal is to facilitate the use of health data for patient care, as well as its secondary use for research, innovation, and public policy development.
In practical terms, this framework is expected to simplify access to and the sharing of electronic health records among member states, while enabling researchers and public institutions to work with large cross-border datasets under common governance rules. European policymakers view the EEDS as a key component of the EU’s digital strategy and a tool for strengthening competitiveness in the fields of artificial intelligence and biotechnology.
In many ways, the Health Data Hub can be seen as a precursor to this model. Both initiatives are based on the observation that data fragmentation limits innovation and public health capabilities. Both rely on the secure sharing of sensitive medical information. And both raise questions about governance, trust, and sovereignty.
Future Challenges
The French experience highlights the challenges that the European Health Data Space will face at the European level.
First, Europe remains heavily dependent on a small number of non-European cloud service providers. Even when data is stored in Europe, concerns remain regarding extraterritorial access to that data under foreign laws.
Second, public trust remains essential. Health data is among the most sensitive types of personal information, and public acceptance of data-sharing initiatives depends on trust in transparency, accountability, and control.
Finally, policymakers must strike a balance between innovation and fundamental rights. The European Health Data Space promises considerable benefits for medical research and the development of artificial intelligence, but the large-scale reuse of data also raises concerns about misuse, unequal power dynamics between public institutions and technology companies, and democratic oversight. Recent studies have also highlighted the importance of governance, transparency, and public trust for the long-term legitimacy or validity of European health data-sharing initiatives.
