Data privacy and protection has been a trending topic in recent years. The COVID 19 pandemic has brought about additional challenges and tensions. For example, sharing health data across several organizations is crucial for significant control and reduction of massive infection and death risks. This implies the need for broadly collecting and using personal and sensitive data, which raises the complexity of data protection and privacy challenges. Permissioned blockchain technology is one way to empower users in controlling how their data flows through the net, in a transparent and secure way, through an immutable, unified, and distributed database ruled by smart contracts. Given this background, we developed a second layer data governance model for permissioned blockchains based on the Governance Analytical Framework principles to be applied in pandemic situations. The model has been designed to organize the relationship between data subjects, data controller, and data processor. Regarding privacy concerns, our proposal complies with the Brazilian General Data Protection Law.
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