Abstract

The growing significance of digital governance in healthcare highlights the importance of secure and ethical medical data sharing. Within the Association of Southeast Asian Nations (ASEAN), member states have introduced personal data protection laws, yet divergences in scope, cross-border transfer rules, and health data exceptions create challenges for harmonization. This study adopts a qualitative research design, combining legal analysis, comparative review, and case-based examination, to evaluate ASEAN frameworks—including the ASEAN Data Management Framework (ADMF) and Model Contractual Clauses (MCCs)—against international mechanisms such as the OECD Recommendations on Health Data Governance, the European Health Data Space (EHDS), and the World Health Organization’s International Health Regulations (IHR). Findings indicate that while ASEAN’s legal infrastructure reflects shared principles of accountability and security, differences in implementation limit regional interoperability. To address these gaps, the paper proposes five coordination pathways: contractual harmonization, regional codes of conduct, adoption of privacy-enhancing technologies (PETs), establishment of emergency fast-track protocols, and development of governance models such as Data Access Committees (DACs) and ethical review boards. By integrating legal, technological, and governance dimensions, ASEAN can position itself as a trusted hub for secure medical data collaboration, advancing both regional integration and global health resilience.