Building up the “Accountable Ulysses” model. The impact of GDPR and national implementations, ethics, and health-data research: Comparative remarks.

The paper illustrates obligations emerging under articles 9 and 89 of the EU Reg. 2016/679 (General Data Protection Regulation, hereinafter “GDPR”) within the health-related data pro- cessing for research purposes. Furthermore, through a comparative analysis of the national implementations of the GDPR on the topic, the paper highlights few practical issues that the researcher might deal with while accomplishing the GDPR obligations and the other ethical requirements. The result of the analyses allows to build up a model to achieve an acceptable standard of accountability in health-related data research. The legal remarks are framed within the myth of Ulysses