Interesting, I now can't find the version I clipped that paragraph version from yesterday! I'm not sure they're materially different, although the one from your link looks more comprehensive. The bit about consent is oddly phrased but I think its written in the context that consent is likely being given for other reasons but in any case consent can be withdrawn. Ultimately privacy rights are determined by the GDPR in the UK. In any case if it's truly anonymised data then the GDPR doesn't apply (Recital 26). I'm not too sure what they mean by an "anonymous code". That could mean it's really pseudonymised data but provided the link from the anonymous code to the PII stays in the UK, which it will as it states only anonymised data is exported to the US, I personally wouldn't be worried about it. It's also possible the US HIPAA legislation would apply and protect the data as it's medical research, but I'm not familiar with that at all.I may also have been wrong about the CCPA covering Stanford. If the data's processed in the context of a not for profit educational research establishment it probably is out of scope, if it's processed by a for profit business owned by Stanford it probably would be subject to CCPA. Guidance is not entirely clear, possible one point to be tested by lawyers in the Californian courts?I'm impressed you read and queried it. I mean that seriously, a lot of business people, for example, use "free software" in a business environment without reading T&Cs or PPs and don't realise the risks.
Michael Ixer ● 2396d