23 March 2026
In the paper, Shabani and Kogut – Czarkowska take a closer look at the legal dimensions of health data sharing through federated networks. In these networks, instead of sending data to a central location, partners collaborate by sharing and analyzing data while the data remains stored in different locations, reducing the need for data transfer and thereby better protecting privacy.
Based on in-depth interviews with 19 experts involved in developing federated data infrastructures, the paper explores how stakeholders interpret and implement key legal obligations such as those in the European Health Data Space and the General Data Protection Regulation in federated networks.
Although Federated Networks are promising to address some of the challenges with health data sharing, they still need to abide by various applicable regulatory frameworks and overcome their sustainability issues, among others.Mahsa Shabani
Although this method of data sharing is often seen as a silver bullet for avoiding legal challenges, Shabani and Kogut–Czarkowska argue that there are still significant challenges in aligning federated networks with data protection requirements. Although federated models are valuable because they enable collaboration and bring new stakeholders into the data-sharing ecosystem, they do not eliminate the need for careful legal design and robust governance.
Shabani and Kogut–Czarkowska encourage discussions on the structure of legal responsibility and governance, the complexity of maintaining data within a single network, and associated technical issues.