Article 5

Right of natural persons to insert information in their own EHR

In short: Natural persons shall have the right to insert information in the EHR.

Natural persons, or their representatives referred to in Article 4(2), shall have the right to insert information in the EHR of those natural persons through electronic health data access services or applications linked to those services as referred to in that Article. That information shall be clearly distinguishable as having been inserted by the natural person or by his or her representative. Natural persons, or their representatives referred to in Article 4(2), shall not be able to directly alter the electronic health data and related information inserted by health professionals.

EHDS Recital 12: In order to complement the information available to them, natural persons should be able to add electronic health data to their EHRs or to store additional information in their separate personal health record which could be accessed by health professionals. However, information inserted by natural persons might not be as reliable as electronic health data entered and verified by health professionals and does not have the same clinical or legal value as information provided by health professionals. Therefore, data added by natural persons in their EHR should be clearly distinguishable from data provided by health professionals. That possibility for natural persons to add and complement personal electronic health data should not entitle them to change personal electronic health data which have been provided by health professionals.

From a DG SANTE presentation: Such information will be separately marked. Implemented through data access services or apps connected to them.

Discussion

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