The Israeli Ministry of Health (“MoH”) disclosed its agreement with pharmaceutical giant Pfizer, which governs the sharing of statistical or de-identified medical information to “measure and analyze epidemiological data arising from the [Pfizer-BioNTech COVID-19 vaccine] rollout, to determine whether herd immunity is achieved reaching a certain percentage of vaccination coverage in Israel”.
The agreement was published due to growing public criticism of the lack of transparency as to what personal data will be disclosed to Pfizer about individuals who are vaccinated. Under the agreement, the MoH will only provide Pfizer with aggregate epidemiological data that cannot reasonably identify an individual as per the Israeli Privacy Protection Law and the Israeli Patient’s Rights Law. If identifiable data is accidentally disclosed to Pfizer, Pfizer is committed to return and delete such data. Pfizer also commits to using the data only for public health purposes and to not use the data in a discriminatory way.
Unpersuaded by the agreement’s safeguards, the Israeli Supreme Helsinki Committee for Clinical Trials in Humans, which is the Israeli statutory committee for approving clinical trials, announced that it deems the data-sharing project subject to the Public Health Regulations (Clinical Trials in Humans), 5740-198, which required the committee’s approval. In response that MoH said that it has reached its own authoritative determination that no committee approval is required given that the collaboration with Pfizer is neither a “research” nor a “clinical trial”.
CLICK HERE to read the redacted version of the agreement between the Israeli Ministry of Health and Pfizer, as published by the MoH.