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In brief

The Subsecretary of Open Government and Digital Country (“Subsecretaría de Gobierno Abierto y País Digital”), dependent on the Chief of Cabinet of Ministers (“Jefatura de Gabinete de Ministros”), created the Vacunación COVID-19 database by means of Disposition No. 06/2021, published in the Official Gazette on 21 April 2021. Its purpose is to organize, accelerate and make effective the administration of vaccines authorized by the competent entities and jurisdictions against COVID-19, contributing to the prevention of the virus and the limitation of its health consequences.

The database will be implemented in accordance with the guidelines set forth by Law No. 25,326 on Personal Data Protection. The database will be a digital file containing personal data of the Cuid.AR app users who request and obtain an appointment to receive any of the approved vaccines against COVID-19 (including, national identity document, sex, province, postal code, cell phone, e-mail, vaccination center, assigned date of vaccination, type of vaccine to be applied and the number of doses to be applied).

The Subsecretaría de Gobierno Abierto y País Digital, in its capacity as the responsible body for the database, will assign, in a disassociated manner whenever possible, the personal data provided by the users to the jurisdictions, entities and agencies of the National Public Administration (according to the section 8, subsections a), b) and c), of Law No. 24,156 on Financial Administration and Public Sector Control Systems), in accordance with section 1 of Administrative Decision No. 431/2020 issued by the Jefatura de Ministros de la Nación.

In all cases, the assignment of data will be made exclusively in the context of the health emergency declared by Decree of Necessity and Urgency No. 260/2020 and within the framework

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Vanina Caniza is a partner in Baker McKenzie’s Buenos Aires office. She advises clients in a variety of corporate and commercial law matters, with extensive experience in corporate compliance, commercial agreements and mergers & acquisitions. She represents and advises Argentine and foreign companies. She completed postgraduate courses on Biotechnology at Universidad Torcuato di Tella (Buenos Aires) and on Health Law at Universidad de Buenos Aires. She sits on the Steering Committee of the Firm’s Latin America Corporate Compliance Group and on the Steering Committee of the Firm’s Latin America Pharmaceuticals & Healthcare Industry Group. She is currently a professor in the CEC Compliance & Ethics Certification (AAEC-UCEMA).


Roberto Grané is a transactional and regulatory partner in Baker McKenzie’s Buenos Aires office. He has been recognized as a leading practitioner by Chambers Latin America. Clients benefit from his more than 20 years of extensive domestic and international experience. Prior to joining Baker McKenzie, Roberto served as in-house counsel to one of the major telecommunications companies in Argentina, and a law clerk with the Civil Courts of Buenos Aires. He is a professor of contract law at the Buenos Aires University and a visiting professor in several local universities.

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