A rede que promete cuidar, mas pode capturar: governança, interoperabilidade e riscos institucionais da RNDS no Brasil

This working paper critically examines the governance model proposed by Bill No. 5.875/2013 for Brazil’s National Health Data Network (RNDS). The paper argues that the expansion of interoperability in healthcare may increase informational concentration and technological dependency before the State demonstrates sufficient institutional, federative and cybersecurity capacity to sustain such infrastructure safely. Drawing on critical digital infrastructure literature and comparative international experiences, the paper discusses functional centralization, fragmentation of accountability, digital sovereignty and risks associated with large-scale circulation of sensitive health data.