Article 9 Special Category Health Data: Processing Requirements
Health data is classified as special category personal data under GDPR Article 9, subject to enhanced protections and restrictions on processing. Any analytics platform processing identifiable patient data for EU health system clients must establish a lawful basis for Article 9 special category data — typically either explicit patient consent (Article 9(2)(a)), vital interests processing (Article 9(2)(c)), or processing for healthcare provision purposes (Article 9(2)(h)) under professional secrecy obligations.
The EU Health Data Space (EHDS) regulation — proposed by the European Commission and advancing through the legislative process — establishes a framework for secondary use of health data across EU member states for research, policy, and quality improvement. Health data holders (hospitals, health systems, registries) will be required to make data available through National Health Data Access Bodies.
Vizier operates as a data processor under Article 28 GDPR when processing health data on behalf of EU health system clients. Data Processing Agreements, sub-processor lists, data residency options within the EU, and Records of Processing Activities (RoPA) are provided to all EU clients as standard contractual documentation.
The Cross-Border Healthcare Directive grants EU patients the right to seek healthcare in other member states and be reimbursed at home country rates. Analytics tracking cross-border patient flows, quality outcomes for international patients, and reimbursement claim volumes are increasingly relevant for border-region hospitals in Germany, France, Belgium, and the Netherlands.
DRG Analytics Across Major European Systems
European DRG systems share common principles but differ significantly in coding standards, payment calculation, and update cycles. Vizier's EU analytics layer is configured for each national system independently.
German Diagnosis-Related Groups
The G-DRG system is updated annually by InEK (Institut für das Entgeltsystem im Krankenhaus). Approximately 1,300 DRGs with base case values varying by hospital. Hauptdiagnose, Nebendiagnose, and procedure coding accuracy directly determines DRG assignment and hospital revenue.
Groupes Homogènes de Malades
The French system uses GHMs (patient groups) which map to GHS (homogeneous care groups) for payment. T2A (tarification à l'activité) is the activity-based funding model. Accurate CIM-10 diagnosis coding and CCAM procedure coding are prerequisites for correct GHM assignment.
Italian Diagnosis-Related Groups
Italy uses a DRG system based on ICD-9-CM coding, though a transition to ICD-10 coding is underway in most regions. Regional variation in base tariffs is significant — Lombardia, Veneto, and Emilia-Romagna have higher base rates than southern regions.
Diagnose Behandel Combinatie
The Dutch DBC-DOT system groups care episodes by diagnosis and treatment combination. Used for both hospital and specialist outpatient care. Free market pricing for many DBC categories introduces competitive analytics requirements not present in other EU systems.
HSMR Benchmarking and European Quality Indicators
The Hospital Standardised Mortality Ratio (HSMR) is the primary comparative quality metric used by European health systems to assess hospital mortality performance. HSMR compares the observed number of deaths in a hospital against the expected number based on case mix, producing a ratio where 100 indicates expected performance, below 100 indicates better-than-expected mortality, and above 100 indicates worse than expected.
The European Hospital and Healthcare Federation (HOPE) and ECDC (European Centre for Disease Prevention and Control) both maintain quality indicator frameworks that Vizier maps to institutional data. ECDC infection surveillance metrics — particularly healthcare-associated infections (HAI) including MRSA, VRE, and C. difficile rates — are tracked as standard quality indicators.
GDPR-Compliant Analytics Built for European Health Systems
GDPR Article 9 compliant data processing, national DRG system analytics (G-DRG, GHM, Italian DRG), HSMR benchmarking, and EU Health Data Space readiness — with EU data residency and standard Data Processing Agreements.