1. The Commission deals most extensively with Article 2 ECHR, while in later jurisprudence, it develops a preference for approaching such matters from the perspective of Article 8 ECHR.
2. The Commission accepts a legal person (association) as a claimant, while in later jurisprudence, it would deny legal person’s a claim under Article 8 ECHR, tressing that only natural persons enjoy privacy (a stance which it only denounced in 2002 in the Stes Colas judgement).
3. The Commission struggles a bit with dealing with the case either as a matter of a negative or a possitive duty by the state. It seems as though the applicant primarily points to a possitive obligation – namely to provide adequate information to citizens – but the Commission finds primarily that the scene was necessary in a democratic society for the protection of health. It stresses that it was a voluntary scheme. With respect to the positive obligation to provide adequate information to ensure informed consent – an obligation the Commmission and the Court would later accept – the Commission stresses that it is ok for the state to leave this up to the parents themselves or the clinical professionals involved.