Gaps #94313
openCLINICARE > PDPA RESTRICTION
0%
Description
DESCRIPTION :
To comply with PDPA (Personal Data Protection Act) and replicate confidentiality safeguards of the traditional BHT (Bed Head Ticket) environment, the HIS/EMR system must restrict access to patient records only to healthcare personnel directly involved in the patient’s care journey.
REQUIREMENT:
Implement department-level access control:When a patient is registered, referred, admitted, or transferred to a department, only authorized users within that department may view and document in the patient’s record.
Departments not involved in the patient’s current episode of care must be denied access unless explicitly authorized.
Ensure continuity of care during ward rounds, shift changes, on-call coverage, and multidisciplinary management while maintaining confidentiality restrictions.
System must log access events (who, when, which department) for all patient notes.
Unauthorized access attempts should trigger clear error messages (e.g.“Access Denied – PDPA Restriction”).
Access rules must remain consistent across modules (OP, ED, IP,).
1. Alignment with PDPA & BHT Confidentiality
In a paperbased BHT environment, only staff directly handling the patient’s file could view or write in it.
Translating this principle into EMR requires restricting access to personnel clinically involved in the patient’s care episode.
This prevents “open access” across the hospital, reducing risk of unauthorized viewing and ensuring compliance with PDPA confidentiality obligations.
Anyone currently involved in the patient's care can access the record, for example:
Primary care team (treating doctors of the involved department).
Nurses assigned to the patient (primary team nurses)
Allied health staff if pt is referred to (physiotherapy, dietitian, pharmacist, etc.)
Doctors who receive referrals (referred department)
2. Clinical Workflow Continuity
Ward rounds & shift changes: Departmentlevel access ensures all onduty staff can view and update records without delay.
Oncall coverage: Authorized oncall staff inherit access rights for the department they are covering.
Multidisciplinary management: If multiple departments are involved (e.g., Surgery + ICU + Radiology), each participating department gains controlled access.
3. Security & Audit Requirements
Audit trail: Every access event must be logged (user ID, department, timestamp, patient record accessed).
Unauthorized attempts: Must trigger error messages and be logged for compliance review.
Granularity: Access should apply across modules (OPD, ED, IPD, Disposition, Lab, Imaging) consistently.
4. Exceptions & Overrides
Emergency override (“break glass”): In lifethreatening situations, authorized clinicians may override restrictions, but system must log justification.
Administrative access: Limited to HIS administrators for troubleshooting, with strict audit logging.
5. Benefits of This Approach
Protects patient confidentiality while ensuring clinical practicality.
Reduces risk of data misuse or accidental disclosure.
Provides clear compliance evidence for audits and PDPA enforcement.
Mirrors traditional paperbased confidentiality practices while leveraging EMR efficiency.
6.System Alerts
Automatic prompts remind users about PDPA compliance when exporting or printing patient data.