RANZCR Submission to the Framework for the Secondary Use of My Health Record Systems Data Consultation

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RANZCR has been involved in policy work and consultations on My Health Record since the Record’s initial inception, and has been working with the Australian Digital Health Agency to improve communication flows and reduce unnecessary duplication of imaging studies.

RANZCR suggests the following safeguards as a minimum:

  • Sharing of data within Australia only
  • No revenues for government agencies from sharing of this information, since that would create perverse incentives for dissemination of sensitive information
  • A clear and unambiguous definition of usage for public health purposes, which is demonstrably in the public interest, to be considered and applied by an ethics committee
  • Binding contractual penalties including criminal penalties for misuse
  • Approved users of secondary data bound by undertakings on confidentiality
  • Information not being made available to parties with commercial interests
  • Debar subsequent sharing of information with other agents or companies. 

Published November 2017