I v Finland ECHR case is also relevant - it concerns the need for complete audit logs in order to evidence no unauthorised access. In that case HIV patient also worked at same hospital and colleagues learned of condition but logs only retained records of most recent access.
http://hudoc.echr.coe.int/eng?i=001-87510#{"itemid":["001-87510"]}
Lynn
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: Tuesday, 22 September, 2015 12:07 PM
To: [log in to unmask]
Subject: Re: [data-protection] Audit log entries - personal data?
Can I belatedly add that whatever the law requires, and whatever the practice in other sectors, the intention and expectation in the NHS is that this will be disclosed.
IG Toolkit requiement 205 Guidance is quite specific "Systems should ahve audit trails that detail anyone and everyone who has accessed a service user's record. Information about who has accessed an individual's record should be made available in a suitable form if requested ... ".
Also the NHS / NIB roadmap document "Personalised Health and Care 2020" has this in the case study on P47 "Jane will be able to see who has accessed her patient record and why"
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