Flexible and collaborative regulation close to the field
In 2021, the CNIL decided to complement its traditional tools to support innovation with the implementation of a “sandbox”, in a logic of flexible and open regulation on emerging issues. This system provides enhanced support for selected innovative projects close to the field in 2022. The aim is to provide innovators with pragmatic answers and legal certainty on new issues.
The CNIL sandbox is open to all innovative projects, regardless of the status (public or private) of the person in charge of the project, its size, its maturity (start-up or not). To be really useful, it is not aimed at projects that are already operational or commercialized.
Digital tools in the education sector, the theme for 2022
For the 2022 version of the “sandbox”, the choice of the CNIL fell on the issue of digital tools used in the education sector. This subject presents strong current issues (in particular for the continuity of school and university education during the pandemic), economic (the EdTechs they are today a thriving sector of French and European innovation) as well as major social challenges in terms of people’s rights (children’s rights, school inclusion, etc.).
The implementation of this “sandbox” will allow a better appropriation, by the education sector, of the issues of compliance with the GDPR, necessary for the development of offers that respect privacy in the context of public procurement. It will also allow the deployment of trusted school and university solutions for users (teachers, students, parents, students, establishments, etc.).
This issue is, finally, marked by a strong dimension of public interest and consolidates the CNIL’s collaboration with the Ministry of National Education, Youth and Sports and the links established with the associations that represent the private actors in the sector ( EdTech France, AFINEF).
A transparent procedure
This year, the CNIL’s “sandbox” is open to five innovative projects. To select the winners, a call for projects is open until February 25, 2022. The benefits provided for in the plan, the selection bases and the content of the application file are available at cnil.fr.
Mainly four criteria will be taken into account: the interest of the project for the public, a strong commitment of the project manager to compliance with the GDPR, a project still in the design phase and the interest in data protection of the questions that are asked. raises the project.
Once the applications have been examined, an evaluation committee made up of CNIL members and qualified external personalities will meet to interview those responsible for the project that best fit the CNIL’s priorities.
For the five projects finally selected by the president of the CNIL, the reinforced support is expected to be extended until the end of 2022.
“Sandbox” 2021: a first successful experience
In 2021, the CNIL’s “sandbox” was dedicated to digital health and wellness data. It has supported four innovative projects, both private and public, initiated in different regions of France, on use cases ranging from help with prescriptions in oncology, to federated learning by algorithms on research data , through the establishment of anonymous indicators for the description of healthy populations and a virtual reality solution for the fight against eating disorders.
This system was a great success, with more than 60 candidates, 4 supported projects, but also, for unselected projects, several support meetings and informative webinars aimed at the innovative ecosystem.
The CNIL will soon publish the lessons learned from these exchanges to complete its doctrine so that all health innovators can benefit.
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