So, setting aside the names of staff who have accessed the record, it is definitely the case that the audit log entries pertaining to the patient are themselves the patient's personal data?
Actually, today, I am working on the assumption that they are not. To quote Durant (other legal authorities are available): "Subject Access] is not an automatic key to any information, readily accessible or not, of matters in which he may be named or involved." And to paraphrase the same case "The log is not about the patient it is about his medical records".
Tomorrow I will believe they are. To quote Durant (other legal authorities are available): "the purpose of section 7,... is to
enable him to check whether the data controller’s processing of it unlawfully infringes his privacy and, if so, to take such steps as the Act provides" and the log certainly is relevant to that task.
In practice I am not going to worry which is correct. I think the right and ethical course of action is pretty clear and providing you give proper attention to fair processing vis-a-vis staff there is really no problem. If they are genuinely not aware that such information may be disclosed now is the time to educate them before we have full Electronic Health Records.
It doesn't have to be like care.data ...
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