Unfortunately it has been on the cards for weeks. Now it seems it will happen after all: a private restart of the Dutch national Electronic Health Record (Elektronisch Patiëntendossier, EPD). Albeit under the name ‘personal health record’ (privacy by semantics), which at first will above all be used ‘regionally’ and only with the permission of each individual patient. However, the underlying infrastructure (National Switch Point, in Dutch: Landelijk Schakelpunt, LSP) is still national in orientation and was voted down unanimously by the Dutch Senate earlier this year due to privacy objections. So by now the private EPD looks suspiciously like a nuclear transport with the LSP as its radioactive cargo. In anticipation of this development, Privacy First has recently (shortly before the reporting deadline) raised some issues with the United Nations Human Rights Council in Geneva. At the end of May 2012, the Dutch human rights situation (including Dutch national privacy policy) will be on the agenda there. The Netherlands will then have to publicly explain which solutions it has found to still safeguard privacy around the EPD. For instance by implementing privacy by design in the coming months through technical compartmentalization, data minimalization, freedom of choice and transparency for patients. In that case perhaps the Netherlands will cut a good figure in Geneva after all...