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. 2023 Jun 24;10:404. doi: 10.1038/s41597-023-02256-2

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© The Author(s) 2023

Open Access This article is licensed under a Creative Commons Attribution 4.0 International License, which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons license, and indicate if changes were made. The images or other third party material in this article are included in the article’s Creative Commons license, unless indicated otherwise in a credit line to the material. If material is not included in the article’s Creative Commons license and your intended use is not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission directly from the copyright holder. To view a copy of this license, visit http://creativecommons.org/licenses/by/4.0/.

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Fig. 1 — Legal bases for processing ‘special category’ personal data relevant to observational retrospective health research purposes from GDPR Article 9 (2). Implementation of the legal bases can differ between European countries. More elaborate descriptions of the legal bases and their implementations can be found in the Supplementary section on Pseudonymisation – GDPR applicable¹⁴.