The German data protection supervisory authorities have released their take on international data transfers in medical research. With its guidelines published in September 2025, the Data Protection Conference (DSK) specifies the requirements of the GDPR for cross-border data transfers for research purposes. The guidelines are primarily intended for research institutions, university hospitals, contract research organizations (CROs), and sponsors of clinical trials, but their relevance may extend across Europe to stakeholders engaged in research activities.

The publication represents a noteworthy reference point in a landscape where international collaboration and the use of medical data are increasingly central to scientific advancement. The DSK attempts to strike a balance between freedom of research and data protection law – with a clearly structured, practice-oriented regulatory framework.

Click here to read the full GT Alert.

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Photo of Dr. Philip Radlanski Dr. Philip Radlanski

Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on privacy and cybersecurity issues. His work focuses on complex and innovative data-heavy projects, often with cross-border aspects. He also

Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on privacy and cybersecurity issues. His work focuses on complex and innovative data-heavy projects, often with cross-border aspects. He also assists with addressing cybersecurity issues, including data breach incident management and response. He gained strong recognition throughout Europe for his representation in the first German trial against a GDPR fine, in which he was able to achieve a reduction of the multimillion-euro fine by more than 90 percent.

Philip is known for his pragmatic approach, which he was able to further refine through several months of secondments to the legal departments of a leading German internet service provider and an internationally operating online marketplace for food delivery. A further one-year secondment to the Global Privacy & Data Security Group of an international law firm in New York shaped Philip’s understanding of the U.S. market and U.S. clients.

Prior to practicing as an attorney, Philip worked as a research assistant at the University of Regensburg, Germany, and as a visiting tutor at King’s College London, UK. He also worked with the German Federal Film Board, the cybercrime division of the Berlin District Attorney’s Office, and for different international law firms in Berlin, New York, and Sydney.

He is a member of the German Association for the Protection of Intellectual Property and Copyright (GRUR), the International Technology Law Association (ITechLaw), and the Bauhaus Archive.

Photo of Dr. Christian Rybak Dr. Christian Rybak

Christian Rybak is a Shareholder in the Public Law Group in Germany and Chair of the German Health Care & Life Science Practice at Greenberg Traurig. He is a leading practitioner in medical and health care law, in health policy and public policy…

Christian Rybak is a Shareholder in the Public Law Group in Germany and Chair of the German Health Care & Life Science Practice at Greenberg Traurig. He is a leading practitioner in medical and health care law, in health policy and public policy advice for the healthcare and life sciences industry. With over two decades of experience, he combines legal experience, comprehensive market knowledge and strategic vision to provide comprehensive advice to companies, institutions, government organizations and service providers on how to overcome legal, regulatory, and economic challenges. His clients include well-known pharmaceutical companies and medical device manufacturers, food and cosmetics manufacturers, government agencies and ministries.

In addition to market access and reimbursement, his areas of expertise include health policy issues, regulatory affairs and compliance, aspects of competition and drug advertising law, as well as strategic and regulatory legal advice.

Before joining Greenberg Traurig, Christian Rybak was a partner at Ehlers, Ehlers & Partner and worked for international law firms in Munich, San Francisco, and Detroit, among other places.