Differences Between Europe and the United States on AI/Digital Policy: Comment Response to Roundtable Discussion on AI - Pierre-Antoine Gourraud, 2020

For AI policy, there are significant differences between Europe and the United States. The General Data Protection Regulation, which applies not only to EU companies but also to all American companies with European customers, is more protective than health insurance portability and accountability act for individual health data. Its Article 22 stipulates that citizens cannot be submitted to medical decisions generated by an automated source. For the creation and implementation of national health databases, European companies have an advantage over the United States because of their small sizes, single-payer systems, and existing national cohorts. For instance, France is in the process of developing a national health data platform (Health Data Hub [HDH]), as part of the Healthcare Law of July 14, 2019.1 It has its origins in the report presented by Cedric Villani to the French government in March 2018.2