Access ServiceAn online service that enables persons to access electronic health dataIn short: The EHDS details a number of online services, to be provided by member states, that enable persons (citizens or healthcare professionals) to access electronic health data. EHDS uses various variations of the term 'access service':
From Article 2: 'electronic health data access service' means an online service, such as a portal or an application for mobile devices, that enables natural persons not acting in a professional capacity to access their own electronic health data or the electronic health data of those natural persons whose electronic health data they are legally authorised to access. From Article 4: Member States shall ensure that one or more electronic health data access services at national, regional or local level are established, thereby enabling natural persons to access their personal electronic health data [free of charge] From Recital 20: Those services could be provided at national, regional or local level, or by healthcare providers, in the form of an online patient portal, an application for mobile devices or by other means. They should be designed in an accessible way, in particular for persons with disabilities. Providing such a service to enable natural persons to have easy access to their personal electronic health data is a substantial public interest. From Article 12: For the provision of healthcare, Member States shall ensure that health professionals are able to access free of charge the priority categories of personal electronic health data referred to in Article 14, including for cross-border care, through health professional access services. LoggingFrom Recital 16: Electronic health data access services should provide detailed information on access to data, such as when and which entity or natural person accessed data and which data were accessed. Natural persons should also be able to enable or disable automatic notifications regarding access to personal electronic health data relating to them through the health professional access services.AuthenticationFrom Recital 29, Article 16: Electronic health data access services and telemedicine services should enable natural persons to exercise their rights regardless of their Member State of affiliation, and should therefore support the identification of natural persons using any electronic identification means recognised pursuant to Regulation (EU) No 910/2014. Given the possibility of challenges regarding identity matching in cross-border situations, it might be necessary for Member States of treatment to provide complementary access mechanisms such as tokens or codes to natural persons who arrive from other Member States and receive healthcare.Proxy servicesFrom Recital 21, Article 4: Natural persons should be able to provide an authorisation to other natural persons of their choice, such as their relatives or other close natural persons, enabling such persons of their choice to access or control the access to the personal electronic health data of the natural persons who provide the authorisation or to use digital health services on their behalf. Such authorisations could also be convenient for other usage by natural persons provided with such an authorisation.Proxy services for enabling and implementing such authorisations should be established by Member States, and be linked to personal electronic health data access services such as patient portals or patient-facing applications for mobile devices. Those proxy services should also enable guardians to act on behalf of their dependents, including minors; in such situations, authorisations could be automatic. In addition to those proxy services, Member States should also establish easily accessible support services to be provided by adequately trained staff dedicated to assisting natural persons when exercising their rights. Comments/Discussion
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