Improved health data governance is urgently needed due to the increasing use of digital technologies that facilitate the collection of health data and growing demand to use that data in artificial intelligence (AI) models that contribute to improving health outcomes. While most of the discussion around health data governance is focused on policy and regulation, we present a practical perspective. We focus on the context of low-resource government health systems, using first-hand experience of the Zanzibar health system as a specific case study, and examine three aspects of data governance: informed consent, data access and security, and data quality. We discuss the barriers to obtaining meaningful informed consent, highlighting the need for more research to determine how to effectively communicate about data and AI and to design effective consent processes. We then report on the process of introducing data access management and information security guidelines into the Zanzibar health system, demonstrating the gaps in capacity and resources that must be addressed during the implementation of a health data governance policy in a low-resource government system. Finally, we discuss the quality of service delivery data in low-resource health systems such as Zanzibar’s, highlighting that a large quantity of data does not necessarily ensure its suitability for AI development. Poor data quality can be addressed to some extent through improved data governance, but the problem is inextricably linked to the weakness of a health system, and therefore AI-quality data cannot be obtained through technological or data governance measures alone.

Fragmentation in health systems leads to discontinuities in the provision of health services, reduces the effectiveness of interventions, and increases costs. In international comparisons, Germany is notably lagging in the context of healthcare (data) integration. Despite various political efforts spanning decades, intersectoral care and integrated health data remain controversial and are still in an embryonic phase in the country. Even more than 2 years after its launch, electronic health record (elektronische Patientenakte; ePA) users in Germany constitute only 1 per cent of the statutorily insured population, and ongoing political debates suggest that the path to broader coverage is fraught with complexities. By exploring the main stakeholders in the existing (fragmented) health system governance in Germany and their sectoral interests, this paper examines the implementation of ePA through the lens of corporatism, offering insights based on an institutional decision theory. The central point is that endeavours to better integrate health data for clinical care, scientific research and evidence-informed policymaking in Germany will need to address the roles of corporatism and self-governance.