Exemptions to data disclosure

Exemptions to data disclosure should be considered in light of WHO’s mandate, existing data-sharing polices, the information disclosure policy, and (with regard to individuals’ rights to privacy and data protection) the United Nations Principles on Personal Data Protection and Privacy and WHO’s personal data protection policy (once adopted), and broader potential risks (whether political, reputational, or related to safety and security or otherwise).

Common legitimate exemptions to open data publication include:

• a specific request from a Member State not to share the data;

• data shared between WHO and third parties, including Member States and implementing partners, where there is an expectation of confidentiality;

• data that, if disclosed, may endanger the safety or security of any individual or have an impact on the exercise of their human rights;

• data that, if disclosed, may endanger the security of a Member State or prejudice the security or conduct of any operation or activity undertaken by WHO;

• data shared, either internally or externally, with the intended use that it be used solely for organizational operations (e.g. draft documents, emails, etc.);

• financial data if disclosure would harm either the financial interests of WHO or a partner;

• data that, if disclosed, would undermine a policy dialogue with a Member State or an implementing partner; and

• other types of data which, because of their content or the circumstances of their creation, must be deemed confidential.

Reference