Strengthen Electronic Health Records System (EHR-S) Access-Control to Cope with GDPR Explicit Consent
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PATIENT FACING SYSTEMS
Strengthen Electronic Health Records System (EHR-S) Access-Control to Cope with GDPR Explicit Consent Marcelo Antonio de Carvalho Junior 1
&
Paulo Bandiera-Paiva 1
Received: 16 July 2020 / Accepted: 28 July 2020 # Springer Science+Business Media, LLC, part of Springer Nature 2020
Abstract Patient consent is currently a missing piece on Electronic Health Records System (EHR-S) access permission. The control is needed to ensure personal data as the property of the individual, not data controllers or health-care service providers. To cope with this need, in this article, an adaptation of existent Role-Based Access Control (RBAC), including patient-centric control, is described. The revisited feature of existing administrative and supporting RBAC functions allows exclusive control orchestrated by the patient as sole information owner, including the ability to encrypt their data for confidentiality purposes. The additions mimic a Discretionary Access Control (DAC) capability using existing user group membership to vet access over symmetric keys bind to patient’s data via the associated PERMS matrix. Keywords Access-control . RBAC . GDPR
Introduction Securing health-care provisioning includes ensuring the proper use of data from trusted entities. Identity and Access Management (IAM) provides means for digital identity control so that heath-care organizations can better decide over allowed workflow, security constraints that ensures which function or roles related process to be executed by certain users, vigilant monitoring and auditing, and regulation compliance to be met. In this scenario, IAM can incorporate different access control1 models as a fundamental security mechanism on systems designed to hold health-care information for protecting health-care data. The Personal Health Information (PHI) of patients, sometimes called private health information, represents the largest proportion of the data content of Electronic Health Record Systems (EHR-S). Personal Health Information, as the name implies, should be governed by its owner.2 However, when it comes to IAM and access-control implementation on EHR-S, this is not a common scenario. Mostly governed by access-control models managed by a This article is part of the Topical Collection on Patient Facing Systems * Marcelo Antonio de Carvalho Junior [email protected] 1
Universidade Federal de São Paulo, São Paulo, SP, Brazil
centralized entity within health-care organization, the capabilities offered to patients to control and decide over its own records is rarely found available.3 The Personal Health Information Protection Act (PHIPA) from 2004, and nowadays the General Data Protection Regulations (GDPR), from 2016, they both establish requirements for data manipulation control and certain obligations for health-care systems as data custodians.2–4 Since EHR-S is a specific type of system within the realm of the Health Information System (HIS) ecosystem, devoted to more intensive interaction and use by health-care professional perso
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