Implementing Health Identifiers: A Strategic Information Governance Perspective (3rd edition)

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The Health Information & Quality Authority (HIQA) recently published their Standards for Health Identifier Operators which will form the basis for the implementation of Health Identifiers in the Irish Health Service.

Since then, the European Court of Justice has issued two cases with potentially significant implications for the data privacy governance of Health Identifiers, and the EU Data Protection Supervisor has issued an Opinion on Ethics in Big Data which also raises issues to be considered in the context of the rollout of Health Identifiers in Ireland.

Castlebridge has conducted a line by line review of the Health Identifiers Act 2014 and the HIQA standards in both their draft and final form. Our review has looked at the Information Governance and Data Protection issues, challenges, and opportunities in the implementation of Health Identifiers. This edition of the Report reviews that analysis again in the context of the CJEU rulings in Bara and Schrems, and the EDPS opinion on Ethics.

This edition consists of approximately 20% additional content, including an assessment on a section by section basis of the implications of Schrems and Bara on the effective operation of the Health Identifiers Act 2014.