Interoperability of contact tracing apps in EU and data protection law implications

This paper offers an outlook of the EU policy response in relation to the interoperability of contact tracing apps and the respective implications for data protection law. First, the paper reviews the relevant communications by the EU institutions, agencies and digital health networking platforms. Secondly, it explains how the use of the term ‘contact tracing’ is perceived in the contact tracing application context. The need for interoperability and the consequent complications for data protection law are further elaborated upon. Lastly, the paper studies cross-border interoperability in connection to already existing and deployed self-acclaimed contact tracing applications.