ICT in the service of public health: fighting Covid – 19 through “app hits”

Curated by Andrea Lensi, Chiara Giannella and Dafne Chillemi

On March 23rd, the Government[1] promoted the “Innova per l’Italia” initiative, a “call” addressed to private and public entities with the aim of identifying the best digital solutions – concrete, already implemented and suitable for rapid implementation – using data analytics, artificial intelligence and big data systems.

In particular, these are applications (so-called “apps”) for telemedicine and home care to patients infected with the SARS – CoV – 2 (“Covid – 19”) virus, such as chatbots that allow self-monitoring of health conditions, as well as apps that use geolocation techniques for tracking the risk of contagion, with requirements for interoperability with corporate and/or regional systems and user friendly methods for identification, authentication, information and any informed consent issued by the user.

In order to evaluate the data driven solutions sent in response to the call, a multidisciplinary task force of 74 professionals divided into eight sub-groups has been operational since April 1st, 2020[2]. These sub-groups will in turn report their findings to the final evaluation group composed of experts[3] from the independent authorities AGCM, AGCOM and Garante Privacy who will deal with the final report to be submitted to the Minister for Technological Innovation and Digitization.

The assumption underlying the Government’s decision and which has guided the task force’s activities lies in the belief that the application of sophisticated data analytics techniques and data sharing is necessary for a more efficient design of actions aimed at curbing the spread of the virus.

Specifically, the members of the task force were asked to evaluate and choose from over three hundred proposals for the use of geolocation systems and monitoring of epidemiological contagion submitted during the call.

Among the latter was the solution proposed by the Italian telecommunications company Vetrya – with the support of the National Interuniversity Consortium for Telecommunications (“CNIT”) – which, using the bluetoooth[4] technology of smartphones and a mapping system based on artificial intelligence, would be able to detect the correlation between individuals and track the trend of Covid-19.

While waiting for a shared solution, there were also regional initiatives, such as the one promoted by the Lombardy Region through the application “AllertaLOM”, developed by the regional holding Aria S.p.A. in collaboration with the infectivologist Raffaele Bruno and the virologist Fausto Baldanti, respectively from the Policlinico San Matteo and the University of Pavia. The application was conceived on the basis of the completion of a questionnaire aimed at collecting a series of fundamental parameters (such as age, the clinical condition of the user, the habits adopted during the quarantine period, if he does not work or if he benefits from smartworking, etc.), all strictly anonymously (according to what stated by the Councillor for Innovation of Lombardy Fabrizio Sala).

The reserve was then finally dissolved on April 16th, when the Commissioner for Emergency Domenico Arcuri signed the Ordinanza n. 10 of 2020, which provides for the free license to use the contact tracing software and the free service contract to be stipulated with the company that created the technology, Bending Spoons SpA[5] .

The app is called “Immuni” and could be fundamental for the start of the so-called “phase 2” of health emergency management, linked to the gradual return to “normality” for the Country.

The solution, prima facie, appears to be in line with the recommendations expressed by both the Garante Privacy and the European Commission, i.e. to prefer bluetooth technology instead of geolocation, anonymisation of the database and voluntary use by the population.

In particular, the operation of the app rests on two “cornerstones”: the first, based on the use of bluetooth, which should allow to estimate with an accuracy of about 1 meter the proximity between people.

The second consists, instead, in a section where it is possible to create a sort of clinical journal of the user, who can write down in real time a series of information related to his health status (for example the appearance of symptoms associated with a coronavirus infection).

At this point, if the user is positive for Covid -19, it will be directly the healthcare professionals who will provide a code with which the patient can download on a ministerial server the log of the IDs (anonymous and temporary) with which he has come into contact in the previous days, allowing the platform to automatically send a notification to the devices of people potentially at risk.

The first doubts about the real effectiveness of the solution chosen by the Government were expressed essentially with reference to the choice to make the app download voluntary. The risk is in fact that if the app is not used by a sufficient number of subjects, it will not be possible to reach a sufficient database for the correct functioning of the algorithms that govern the functioning of the software.

With regard to the actual release of the app, the various political forces are asking for it to be subject to the approval, by the national legislator, of a specific regulation. On this point, the Prime Minister said that “(…) the involvement of the Parliament must be full since fundamental constitutional rights are involved, such as the right to public health, confidentiality and the need to protect an information asset of primary importance in the logic of national strategic interests“.

Lastly, on the 21st of April, the European Data Protection Board (“EDPB”) has adopted guidelines on the processing of health data for research purposes in the context of the COVID-19, in order to provide guidance on the most pressing issues, in particular on the legal basis for processing, the further processing of health data for scientific research purposes, as well as the implementation of appropriate safeguards and the exercise of data subjects’ rights[6].

[1] The Minister for Technological Innovation and Digitization Paola Pisano, the Minister of Economic Development Stefano Patuanelli and the Minister of University and Research Gaetano Manfredi, together with the Ministry of Health, the Istituto Superiore di Sanità, the World Health Organization and an interdisciplinary scientific committee.

[2] The ministerial decree of appointment was signed by the Minister for Technological Innovation Paola Pisano.

[3] The members have been appointed by the Ministry of Health, the Istituto Superiore di Sanità and the World Health Organization, the Antitrust Authority (“AGCM”), the Communications Authority (“AGCOM”) and the Italian Data Protection Supervisory Authority (“Garante Privacy”).

[4] The use of bluetooth technology is a choice shared by several operators, not only Italian, but also European and British.

[5] in partnership with Centro Diagnostico Santagostino di Luca Foresti e Jakala.

[6] Guidelines 03/2020 on the processing of data concerning health for the purpose of scientific research in the context of the COVID-19 outbreak.

Let’s Talk

For a deeper discussion, please contact:

Andrea Lensi

PwC TLS Avvocati e Commercialisti


Chiara Giannella

PwC TLS Avvocati e Commercialisti