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Medical Facts, 15 July 2011: 'Privacy First sends fire letter to House of Representatives on EHR'

"Privacy First sent fire letter to SPD spokespersons in House of Representatives

The development of a private national Electronic Patient Record (EHR) must stop. So says Privacy First in an open letter to MPs, in response to the 'relaunch' of the SPD. Privacy First is an independent foundation aiming to preserve and promote the right to privacy. In Privacy First's view, the National Switch Point (LSP) of the L-EPD should be transformed into small-scale regional systems in line with the wishes of the Senate. For regional exchange, an LSP is unnecessary: after all, regional switching points (RSPs), possibly supplemented by supra-regional push-communication. This enhances security and reduces the risks of misuse inherent in an L-EPD.
Privacy First says it is concerned about developments indicating a possible 'relaunch' of this same SPD through private, extra-parliamentary channels. Such a 'relaunch' not only shows contempt for the democratic process, but also denies the risks and concerns on the basis of which legal introduction of a national SPD (L-EPD) recently failed to go ahead, Privacy First argues. Privacy First therefore urges members of the House of Representatives to halt this development and hold the relevant minister accountable. After all, in a privacy-law sense, in Privacy First's view, the Dutch government remains fully responsible for the privacy breaches that will result from a 'private L-EPD', precisely also given the fact that such a system was explicitly rejected by the Senate on privacy grounds.

In line with the recently adopted Franken motion, Privacy First also urges in this regard that an independent, public Privacy Impact Assessment (PIA) into 1) a national EPD as envisioned by the private parties involved and 2) possible alternatives for this L-EPD. In carrying out this PIA, the criteria of necessity, proportionality, subsidiarity and freedom of choice should be leading. An important role in the PIA should be played by privacy by design and privacy enhancing technologies, including, for example, advanced patient passes or personal health records. Until this PIA will be completed, no irreversible steps towards a private relaunch of the L-EPD should be taken."

Source: Medical Facts, 15 July 2011.