La nuova eGovernance sanitaria europea: verso una piena integrazione della digitalizzazione nei sistemi sanitari degli Stati membri

L’elaborato approfondisce il diritto alla salute nell’ordinamento dell’Unione europea, con la consapevolezza che il settore della sanità, nella complessità di una tensione perdurante tra la sua matrice sociale e l’applicazione di logiche europee di mercato, rappresenta un ambito da sempre sottratto all’intervento diretto e vincolante delle istituzioni. Contemporaneamente, prende spunto dall’osservazione della transizione digitale dei sistemi sanitari nazionali per proporre una rilettura dei tradizionali equilibri istituzionali tra ordinamenti e constatare il grado di influenza dell’Unione oltre la dimensione transfrontaliera. Infatti, per le attuali esigenze di sostenibilità dei sistemi di tutela della salute e per il valore aggiunto riconosciuto alle azioni europee nel corso della gestione della pandemia da Covid-19, l’eHealth ha rappresentato l’occasione per una vigorosa intrusione delle istituzioni europee entro prerogative tipicamente statuali, fino all’emersione di una eGovernance sanitaria europea. Pertanto, la trattazione compie un percorso evolutivo che muove dalla Direttiva 2011/24 sull’assistenza transfrontaliera e l’assistenza sanitaria online, in combinato disposto con il complesso degli atti di soft law connessi, per verificarne l’esiguo impatto sui sistemi sanitari degli Stati membri e, alla luce dei recenti investimenti strategici ed interventi normativi rilevanti in tema di tecnologie applicate alla sanità, riconoscerne il sostanziale superamento. In particolare, il confronto tra l’insufficiente livello di digitalizzazione raggiunto finora nei sistemi sanitari degli Stati membri ed il tenore della Proposta di regolamento sullo European Health Data Space suggerisce l’evoluzione dell’impianto di governo dei dati sanitari stabilito nella Direttiva, a partire dalla previsione di una disciplina comune sulla cartella sanitaria. A questo proposito, l’interoperabilità tra tecnologie diviene un presupposto operativo indefettibile, che corrobora la natura ‘tecnologicamente condizionata’ del diritto alla salute e propone l’idea che la sanità digitale rappresenti un passo in avanti verso un’assistenza europea uniforme.

The special rights other than shares in cross-border mergers of limited liability companies within the European Union. A perspective from the Spanish Law

The present research aims to study the special rights other than shares in Spanish Law and the protection of their holders in cross-border mergers of limited liability companies within the European Union frame. Special rights other than shares are recognised as an independent legal category within legal systems of some EU Member States, such as Germany or Spain, through the implementation of the Third Directive 78/855/CEE concerning mergers of public limited liability companies. The above-cited Directive contains a special regime of protection for the holders of securities, other than shares, to which special rights are attached, consisting of being given rights in the acquiring company, at least equivalent to those they possessed in the company being acquired. This safeguard is to highlight the intimate connection between this type of rights and the company whose extinction determines the existence of those. Pursuant to the Directive 2005/56/CE on cross-border mergers of limited liability companies, each company taking part in these operations shall comply with the safeguards of members and third parties provided in their respective national law to which is subject. In this regard, the protection for holders of special rights other than shares shall be ruled by the domestic M&A regime. As far as Spanish Law are concerned, holders of these special rights are recognized a right of merger information, in the same terms as shareholders, as well as equal rights in the company resulting from the cross-border merger. However, these measures are not enough guarantee for a suitable protection, thus considering those holders of special rights as special creditors, sometimes it will be necessary to go to the general protection regime for creditors. In Spanish Law, it would involve the recognition of right to the merger opposition, whose exercise would prevent the operation was completed until ensuring equal rights.

Decentralized systems for the protection and portability of personal data

The General Data Protection Regulation (GDPR) has been designed to help promote a view in favor of the interests of individuals instead of large corporations. However, there is the need of more dedicated technologies that can help companies comply with GDPR while enabling people to exercise their rights. We argue that such a dedicated solution must address two main issues: the need for more transparency towards individuals regarding the management of their personal information and their often hindered ability to access and make interoperable personal data in a way that the exercise of one's rights would result in straightforward. We aim to provide a system that helps to push personal data management towards the individual's control, i.e., a personal information management system (PIMS). By using distributed storage and decentralized computing networks to control online services, users' personal information could be shifted towards those directly concerned, i.e., the data subjects. The use of Distributed Ledger Technologies (DLTs) and Decentralized File Storage (DFS) as an implementation of decentralized systems is of paramount importance in this case. The structure of this dissertation follows an incremental approach to describing a set of decentralized systems and models that revolves around personal data and their subjects. Each chapter of this dissertation builds up the previous one and discusses the technical implementation of a system and its relation with the corresponding regulations. We refer to the EU regulatory framework, including GDPR, eIDAS, and Data Governance Act, to build our final system architecture's functional and non-functional drivers. In our PIMS design, personal data is kept in a Personal Data Space (PDS) consisting of encrypted personal data referring to the subject stored in a DFS. On top of that, a network of authorization servers acts as a data intermediary to provide access to potential data recipients through smart contracts.

Big data analysis systems in IoE environments for managing privacy and data protection: pseudonymity, de-anonymization and the right to be forgotten

The thesis represents the conclusive outcome of the European Joint Doctorate programmein Law, Science & Technology funded by the European Commission with the instrument Marie Skłodowska-Curie Innovative Training Networks actions inside of the H2020, grantagreement n. 814177. The tension between data protection and privacy from one side, and the need of granting further uses of processed personal datails is investigated, drawing the lines of the technological development of the de-anonymization/re-identification risk with an explorative survey. After acknowledging its span, it is questioned whether a certain degree of anonymity can still be granted focusing on a double perspective: an objective and a subjective perspective. The objective perspective focuses on the data processing models per se, while the subjective perspective investigates whether the distribution of roles and responsibilities among stakeholders can ensure data anonymity.

Interactions between normative systems and software cognitive agents. A formalization in temporal modal defeasible logic and its implementation

Sustainable computer systems require some flexibility to adapt to environmental unpredictable changes. A solution lies in autonomous software agents which can adapt autonomously to their environments. Though autonomy allows agents to decide which behavior to adopt, a disadvantage is a lack of control, and as a side effect even untrustworthiness: we want to keep some control over such autonomous agents. How to control autonomous agents while respecting their autonomy? A solution is to regulate agents’ behavior by norms. The normative paradigm makes it possible to control autonomous agents while respecting their autonomy, limiting untrustworthiness and augmenting system compliance. It can also facilitate the design of the system, for example, by regulating the coordination among agents. However, an autonomous agent will follow norms or violate them in some conditions. What are the conditions in which a norm is binding upon an agent? While autonomy is regarded as the driving force behind the normative paradigm, cognitive agents provide a basis for modeling the bindingness of norms. In order to cope with the complexity of the modeling of cognitive agents and normative bindingness, we adopt an intentional stance. Since agents are embedded into a dynamic environment, things may not pass at the same instant. Accordingly, our cognitive model is extended to account for some temporal aspects. Special attention is given to the temporal peculiarities of the legal domain such as, among others, the time in force and the time in efficacy of provisions. Some types of normative modifications are also discussed in the framework. It is noteworthy that our temporal account of legal reasoning is integrated to our commonsense temporal account of cognition. As our intention is to build sustainable reasoning systems running unpredictable environment, we adopt a declarative representation of knowledge. A declarative representation of norms will make it easier to update their system representation, thus facilitating system maintenance; and to improve system transparency, thus easing system governance. Since agents are bounded and are embedded into unpredictable environments, and since conflicts may appear amongst mental states and norms, agent reasoning has to be defeasible, i.e. new pieces of information can invalidate formerly derivable conclusions. In this dissertation, our model is formalized into a non-monotonic logic, namely into a temporal modal defeasible logic, in order to account for the interactions between normative systems and software cognitive agents.

Securitization and Special Purpose Vehicles in an International Setting: a Systemic View

The present work tries to display a comprehensive and comparative study of the different legal and regulatory problems involved in international securitization transactions. First, an introduction to securitization is provided, with the basic elements of the transaction, followed by the different varieties of it, including dynamic securitization and synthetic securitization structures. Together with this introduction to the intricacies of the structure, a insight into the influence of securitization in the financial and economic crisis of 2007-2009 is provided too; as well as an overview of the process of regulatory competition and cooperation that constitutes the framework for the international aspects of securitization. The next Chapter focuses on the aspects that constitute the foundations of structured finance: the inception of the vehicle, and the transfer of risks associated to the securitized assets, with particular emphasis on the validity of those elements, and how a securitization transaction could be threatened at its root. In this sense, special importance is given to the validity of the trust as an instrument of finance, to the assignment of future receivables or receivables in block, and to the importance of formalities for the validity of corporations, trusts, assignments, etc., and the interaction of such formalities contained in general corporate, trust and assignment law with those contemplated under specific securitization regulations. Then, the next Chapter (III) focuses on creditor protection aspects. As such, we provide some insights on the debate on the capital structure of the firm, and its inadequacy to assess the financial soundness problems inherent to securitization. Then, we proceed to analyze the importance of rules on creditor protection in the context of securitization. The corollary is in the rules in case of insolvency. In this sense, we divide the cases where a party involved in the transaction goes bankrupt, from those where the transaction itself collapses. Finally, we focus on the scenario where a substance over form analysis may compromise some of the elements of the structure (notably the limited liability of the sponsor, and/or the transfer of assets) by means of veil piercing, substantive consolidation, or recharacterization theories. Once these elements have been covered, the next Chapters focus on the regulatory aspects involved in the transaction. Chapter IV is more referred to “market” regulations, i.e. those concerned with information disclosure and other rules (appointment of the indenture trustee, and elaboration of a rating by a rating agency) concerning the offering of asset-backed securities to the public. Chapter V, on the other hand, focuses on “prudential” regulation of the entity entrusted with securitizing assets (the so-called Special Purpose vehicle), and other entities involved in the process. Regarding the SPV, a reference is made to licensing requirements, restriction of activities and governance structures to prevent abuses. Regarding the sponsor of the transaction, a focus is made on provisions on sound originating practices, and the servicing function. Finally, we study accounting and banking regulations, including the Basel I and Basel II Frameworks, which determine the consolidation of the SPV, and the de-recognition of the securitized asset from the originating company’s balance-sheet, as well as the posterior treatment of those assets, in particular by banks. Chapters VI-IX are concerned with liability matters. Chapter VI is an introduction to the different sources of liability. Chapter VII focuses on the liability by the SPV and its management for the information supplied to investors, the management of the asset pool, and the breach of loyalty (or fiduciary) duties. Chapter VIII rather refers to the liability of the originator as a result of such information and statements, but also as a result of inadequate and reckless originating or servicing practices. Chapter IX finally focuses on third parties entrusted with the soundness of the transaction towards the market, the so-called gatekeepers. In this respect, we make special emphasis on the liability of indenture trustees, underwriters and rating agencies. Chapters X and XI focus on the international aspects of securitization. Chapter X contains a conflicts of laws analysis of the different aspects of structured finance. In this respect, a study is made of the laws applicable to the vehicle, to the transfer of risks (either by assignment or by means of derivatives contracts), to liability issues; and a study is also made of the competent jurisdiction (and applicable law) in bankruptcy cases; as well as in cases where a substance-over-form is performed. Then, special attention is also devoted to the role of financial and securities regulations; as well as to their territorial limits, and extraterritoriality problems involved. Chapter XI supplements the prior Chapter, for it analyzes the limits to the States’ exercise of regulatory power by the personal and “market” freedoms included in the US Constitution or the EU Treaties. A reference is also made to the (still insufficient) rules from the WTO Framework, and their significance to the States’ recognition and regulation of securitization transactions.

La giustiziabilità dei diritti sociali nell'ordinamento dell'Unione europea

L’oggetto del lavoro si sostanzia nella verifica del grado di giustiziabilità che i diritti sociali ricevono nell’ordinamento dell’Unione europea. L’indagine si articola in tre capitoli. Il primo è dedicato ad una sintetica ricostruzione dei modelli di welfare state riconosciuti dagli ordinamenti dei diversi paesi membri dell’Unione attraverso cui, la candidata enuclea un insieme di diritti sociali che ricevono tutela in tutti gli ordinamenti nazionali. L’esposizione prosegue, con la ricostruzione dell’evoluzione dei Trattati istitutivi dell’Unione e l’inclusione della sfera sociale tra gli obiettivi di questa. In particolare, il secondo capitolo esamina la giurisprudenza della Corte di Giustizia in relazione alle materie sociali, nonché l’inclusione dei diritti sociali nel testo della Carta dei diritti fondamentali. L’analisi si sofferma sulle tecniche normative adottate nell’area della politica sociale, evidenziando la tendenza ad un approccio di tipo “soft” piuttosto che attraverso il classico metodo comunitario. Esaurita questa analisi il terzo capitolo analizza i rapporti tra il diritto dell’Ue e quello della CEDU in materia di diritti sociali, evidenziano il diverso approccio utilizzato dalle due istanze sovranazionali nella tutela di questi diritti. Sulla base del lavoro svolto si conclude per una sostanziale mancanza di giustiziabilità dei diritti sociali in ambito dell’Unione. In particolare i punti deboli dell’Europa sociale vengono individuati in: un approccio regolativo alla dimensione sociale di tipo sempre più soft; la permanenza di alcuni deficit di competenze; la mancata indicazione di criteri di bilanciamento tra diritti sociali e libertà economiche e dalla compresenza delle due nozioni di economia sociale e di economia di mercato. Le conclusioni mostrano come l’assenza di competenze esclusive dell’Unione in materia di politica sociale non consenta una uniformazione/armonizzazione delle politiche sociali interne, che si riflette nell’incapacità dei modelli sociali nazionali di assorbire i grandi mutamenti macro economici che si sono avuti negli ultimi vent’anni, sia a livello sovranazionale che internazionale.

Quantum Correlations in Field Theory and Integrable Systems

In this thesis we will investigate some properties of one-dimensional quantum systems. From a theoretical point of view quantum models in one dimension are particularly interesting because they are strongly interacting, since particles cannot avoid each other in their motion, and you we can never ignore collisions. Yet, integrable models often generate new and non-trivial solutions, which could not be found perturbatively. In this dissertation we shall focus on two important aspects of integrable one- dimensional models: Their entanglement properties at equilibrium and their dynamical correlators after a quantum quench. The first part of the thesis will be therefore devoted to the study of the entanglement entropy in one- dimensional integrable systems, with a special focus on the XYZ spin-1/2 chain, which, in addition to being integrable, is also an interacting model. We will derive its Renyi entropies in the thermodynamic limit and its behaviour in different phases and for different values of the mass-gap will be analysed. In the second part of the thesis we will instead study the dynamics of correlators after a quantum quench , which represent a powerful tool to measure how perturbations and signals propagate through a quantum chain. The emphasis will be on the Transverse Field Ising Chain and the O(3) non-linear sigma model, which will be both studied by means of a semi-classical approach. Moreover in the last chapter we will demonstrate a general result about the dynamics of correlation functions of local observables after a quantum quench in integrable systems. In particular we will show that if there are not long-range interactions in the final Hamiltonian, then the dynamics of the model (non equal- time correlations) is described by the same statistical ensemble that describes its statical properties (equal-time correlations).

Modelling the dynamic response of rockfall protection barriers

Mountainous areas are prone to natural hazards like rockfalls. Among the many countermeasures, rockfall protection barriers represent an effective solution to mitigate the risk. They are metallic structures designed to intercept rocks falling from unstable slopes, thus dissipating the energy deriving from the impact. This study aims at providing a better understanding of the response of several rockfall barrier types, through the development of rather sophisticated three-dimensional numerical finite elements models which take into account for the highly dynamic and non-linear conditions of such events. The models are built considering the actual geometrical and mechanical properties of real systems. Particular attention is given to the connecting details between the structural components and to their interactions. The importance of the work lies in being able to support a wide experimental activity with appropriate numerical modelling. The data of several full-scale tests carried out on barrier prototypes, as well as on their structural components, are combined with results of numerical simulations. Though the models are designed with relatively simple solutions in order to obtain a low computational cost of the simulations, they are able to reproduce with great accuracy the test results, thus validating the reliability of the numerical strategy proposed for the design of these structures. The developed models have shown to be readily applied to predict the barrier performance under different possible scenarios, by varying the initial configuration of the structures and/or of the impact conditions. Furthermore, the numerical models enable to optimize the design of these structures and to evaluate the benefit of possible solutions. Finally it is shown they can be also used as a valuable supporting tool for the operators within a rockfall risk assessment procedure, to gain crucial understanding of the performance of existing barriers in working conditions.

Essays on Innovative Activity and the Protection of Innovations

This dissertation looks at three widely accepted assumptions about how the patent system works: patent documents disclose inventions; this disclosure happens quickly, and patent owners are able to enforce patents. The first chapter estimates the effect of stronger trade secret protection on the number of patented innovations. When firms find it easier to protect business information, there is less need for patent protection, and accordingly less need for the disclosure of technical information that is required by patent law. The novel finding is that when it is easier to keep innovations, there is not only a reduction in the number of patents but also a sizeable reduction in disclosed knowledge per patent. The chapter then shows how this endogeneity of the amount of knowledge per patent can affect the measurement of innovation using patent data. The second chapter develops a game-theoretic model to study how the introduction of fee-shifting in US patent litigation would influence firms’ patenting propensities. When the defeated party to a lawsuit has to bear not only their own cost but also the legal expenditure of the winning party, manufacturing firms in the model unambiguously reduce patenting, with small firms affected the most. For fee-shifting to have the same effect as in Europe, the US legal system would require shifting of a much smaller share of fees. Lessons from European patent litigation may, therefore, have only limited applicability in the US case. The third chapter contains a theoretical analysis of the influence of delayed disclosure of patent applications by the patent office. Such a delay is a feature of most patent systems around the world but has so far not attracted analytical scrutiny. This delay may give firms various kinds of strategic (non-)disclosure incentives when they are competing for more than a single innovation.

Data protection by design in the e-health care sector: theoretical and applied perspectives

In the digital age, e-health technologies play a pivotal role in the processing of medical information. As personal health data represents sensitive information concerning a data subject, enhancing data protection and security of systems and practices has become a primary concern. In recent years, there has been an increasing interest in the concept of Privacy by Design, which aims at developing a product or a service in a way that it supports privacy principles and rules. In the EU, Article 25 of the General Data Protection Regulation provides a binding obligation of implementing Data Protection by Design technical and organisational measures. This thesis explores how an e-health system could be developed and how data processing activities could be carried out to apply data protection principles and requirements from the design stage. The research attempts to bridge the gap between the legal and technical disciplines on DPbD by providing a set of guidelines for the implementation of the principle. The work is based on literature review, legal and comparative analysis, and investigation of the existing technical solutions and engineering methodologies. The work can be differentiated by theoretical and applied perspectives. First, it critically conducts a legal analysis on the principle of PbD and it studies the DPbD legal obligation and the related provisions. Later, the research contextualises the rule in the health care field by investigating the applicable legal framework for personal health data processing. Moreover, the research focuses on the US legal system by conducting a comparative analysis. Adopting an applied perspective, the research investigates the existing technical methodologies and tools to design data protection and it proposes a set of comprehensive DPbD organisational and technical guidelines for a crucial case study, that is an Electronic Health Record system.

Modelling of ORC components and systems for low-medium temperature heat recovery applications with reduced environmental impact

Although its great potential as low to medium temperature waste heat recovery (WHR) solution, the ORC technology presents open challenges that still prevent its diffusion in the market, which are different depending on the application and the size at stake. Focusing on the micro range power size and low temperature heat sources, the ORC technology is still not mature due to the lack of appropriate machines and working fluids. Considering instead the medium to large size, the technology is already available but the investment is still risky. The intention of this thesis is to address some of the topical themes in the ORC field, paying special attention in the development of reliable models based on realistic data and accounting for the off-design performance of the ORC system and of each of its components. Concerning the “Micro-generation” application, this work: i) explores the modelling methodology, the performance and the optimal parameters of reciprocating piston expanders; ii) investigates the performance of such expander and of the whole micro-ORC system when using Hydrofluorocarbons as working fluid or their new low GWP alternatives and mixtures; iii) analyzes the innovative ORC reversible architecture (conceived for the energy storage), its optimal regulation strategy and its potential when inserted in typical small industrial frameworks. Regarding the “Industrial WHR” sector, this thesis examines the WHR opportunity of ORCs, with a focus on the natural gas compressor stations application. This work provides information about all the possible parameters that can influence the optimal sizing, the performance and thus the feasibility of installing an ORC system. New WHR configurations are explored: i) a first one, relying on the replacement of a compressor prime mover with an ORC; ii) a second one, which consists in the use of a supercritical CO2 cycle as heat recovery system.

PCM-based battery thermal management systems, energy saving materials and LCA strategy for automotive

This PhD work arises from the necessity to give a contribution to the energy saving field, regarding automotive applications. The aim was to produce a multidisciplinary work to show how much important is to consider different aspects of an electric car realization: from innovative materials to cutting-edge battery thermal management systems (BTMSs), also dealing with the life cycle assessment (LCA) of the battery packs (BPs). Regarding the materials, it has been chosen to focus on carbon fiber composites as their use allows realizing light products with great mechanical properties. Processes and methods to produce carbon fiber goods have been analysed with a special attention on the university solar car Emilia 4. The work proceeds dealing with the common BTMSs on the market (air-cooled, cooling plates, heat pipes) and then it deepens some of the most innovative systems such as the PCM-based BTMSs after a previous experimental campaign to characterize the PCMs. After that, a complex experimental campaign regarding the PCM-based BTMSs has been carried on, considering both uninsulated and insulated systems. About the first category the tested systems have been pure PCM-based and copper-foam-loaded-PCM-based BTMSs; the insulated tested systems have been pure PCM-based and copper-foam-loaded-PCM-based BTMSs and both of these systems equipped with a liquid cooling circuit. The choice of lighter building materials and the optimization of the BTMS are strategies which helps in reducing the energy consumption, considering both the energy required by the car to move and the BP state of health (SOH). Focusing on this last factor, a clear explanation regarding the importance of taking care about the SOH is given by the analysis of a BP production energy consumption. This is why a final dissertation about the life cycle assessment (LCA) of a BP unit has been presented in this thesis.

Data sensitivity detection in chat interactions for privacy protection

In recent years, there has been exponential growth in using virtual spaces, including dialogue systems, that handle personal information. The concept of personal privacy in the literature is discussed and controversial, whereas, in the technological field, it directly influences the degree of reliability perceived in the information system (privacy ‘as trust’). This work aims to protect the right to privacy on personal data (GDPR, 2018) and avoid the loss of sensitive content by exploring sensitive information detection (SID) task. It is grounded on the following research questions: (RQ1) What does sensitive data mean? How to define a personal sensitive information domain? (RQ2) How to create a state-of-the-art model for SID?(RQ3) How to evaluate the model? RQ1 theoretically investigates the concepts of privacy and the ontological state-of-the-art representation of personal information. The Data Privacy Vocabulary (DPV) is the taxonomic resource taken as an authoritative reference for the definition of the knowledge domain. Concerning RQ2, we investigate two approaches to classify sensitive data: the first - bottom-up - explores automatic learning methods based on transformer networks, the second - top-down - proposes logical-symbolic methods with the construction of privaframe, a knowledge graph of compositional frames representing personal data categories. Both approaches are tested. For the evaluation - RQ3 – we create SPeDaC, a sentence-level labeled resource. This can be used as a benchmark or training in the SID task, filling the gap of a shared resource in this field. If the approach based on artificial neural networks confirms the validity of the direction adopted in the most recent studies on SID, the logical-symbolic approach emerges as the preferred way for the classification of fine-grained personal data categories, thanks to the semantic-grounded tailor modeling it allows. At the same time, the results highlight the strong potential of hybrid architectures in solving automatic tasks.

Internet of healthcare (law): privacy and data protection aspects in an internet of everything

The purpose of this research study is to discuss privacy and data protection-related regulatory and compliance challenges posed by digital transformation in healthcare in the wake of the COVID-19 pandemic. The public health crisis accelerated the development of patient-centred remote/hybrid healthcare delivery models that make increased use of telehealth services and related digital solutions. The large-scale uptake of IoT-enabled medical devices and wellness applications, and the offering of healthcare services via healthcare platforms (online doctor marketplaces) have catalysed these developments. However, the use of new enabling technologies (IoT, AI) and the platformisation of healthcare pose complex challenges to the protection of patient’s privacy and personal data. This happens at a time when the EU is drawing up a new regulatory landscape for the use of data and digital technologies. Against this background, the study presents an interdisciplinary (normative and technology-oriented) critical assessment on how the new regulatory framework may affect privacy and data protection requirements regarding the deployment and use of Internet of Health Things (hardware) devices and interconnected software (AI systems). The study also assesses key privacy and data protection challenges that affect healthcare platforms (online doctor marketplaces) in their offering of video API-enabled teleconsultation services and their (anticipated) integration into the European Health Data Space. The overall conclusion of the study is that regulatory deficiencies may create integrity risks for the protection of privacy and personal data in telehealth due to uncertainties about the proper interplay, legal effects and effectiveness of (existing and proposed) EU legislation. The proliferation of normative measures may increase compliance costs, hinder innovation and ultimately, deprive European patients from state-of-the-art digital health technologies, which is paradoxically, the opposite of what the EU plans to achieve.