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Carlo Petrini
Address for correspondence: Carlo Petrini. Unità di Bioetica, Presidenza, Istituto Superiore di Sanità, Via Giano della Bella 34, 00162 Rome, Italy.
E-mail carlo.petrini@iss.it.
Abstract
Public health programmes pose some very important ethical problems. One of the most
pressing is the possible conflict between individual interests (and rights) and collective
interests, which becomes particularly important in the public health surveillance setting.
The present article first looks at the definitions of “public health surveillance” in a histori-
cal context and then identifies the key ethical problems that are raised. These reveal the
differences – and sometimes deviations – between the bioethical issues typically encoun-
tered in a clinical setting and those that prevail in a public health context. Human rights
are suggested as a possible common ground between the two. The article then draws on
the specialised literature to indicate tools and checklists to help evaluate the ethical ac-
ceptability of public health surveillance programmes. It concludes with a description of
the key criteria underlying these tools and checklists.
Ethics in public health surveillance
Unità di Bioetica, Presidenza, Istituto Superiore di Sanità, Rome, Italy
Ann Ist Super Sanità 2013 | Vol. 49, No. 4: 000-000
DOI
Key words
• autonomy
• bioethics
• informed consent
• public health surveillance
Originalarticlesandreviews
A
HISTORICAL NOTES AND DEFINITIONS
The history of public health surveillance can be
traced back as far as the Renaissance, confirming
that its importance was recognised long before recent
discoveries in the field of infectious diseases and the
elaboration of the diagnostic tools available to today’s
epidemiologists [1].
In 1938 William Farr convincingly described the
importance of public health surveillance with the help
of registers: “Half the life is passed in infancy, sick-
ness and dependent helplessness. In exhibiting the
high mortality, the diseases by which it is occasioned
and the exciting causes of disease, the abstracts of the
Registers will prove that while a part of the sickness
is inevitable and part may be expected to disappear
by progressive social amelioration a considerable pro-
portion may be suppressed by the general adoption
of hygienic measures (...). Morbidity registration will
be an invaluable contribution to therapeutics, as well
as to hygiene, for it will enable the therapeutists to
determine the duration and fatality of all forms of
disease (…). Illusion will be dispelled, quackery (…)
suppressed, a science of therapeutics created, suffer-
ing diminished, life shielded from many dangers” [2].
Around the middle of the last century, when infec-
tious diseases were the most pressing problem for
public health authorities worldwide, Alexander Lang-
muir of the Centers for Disease Control and Preven-
tion (CDC) drew up a programme for the system-
atic surveillance of infectious diseases. In 1963 he
defined surveillance as “the continued watchfulness
over the distribution and trends of incidence through
the systematic collection, consolidation and evalu-
ation of morbidity and mortality reports and other
relevant data. Intrinsic in the concept is the regular
dissemination of the basic data and interpretations to
all who have contributed and to all others who need
to know” [3]. The basic elements underlying the no-
tion of “surveillance” proposed by Langmuir [3] and
later re-elaborated [4] are: 1) systematic and active
collection of pertinent data on target disease(s); 2)
assessment and practical reporting of these data, and
3) the timely dissemination of reports to individuals
responsible for the formulation of action plans.
A few years later Karel Raska of the Communicable
Disease Division at the World Health Organisation
(WHO) extended Langmuir’s definition to include
epidemiological research in surveillance activities [5].
Half a century later the debate as to where the
boundaries of public health surveillance should be
drawn is still unresolved: “In the area of public health
practice, we may need to rethink the boundary of
surveillance systems. It may be wise not to expand it
to a broad investigation or epidemiological research,
which certainly interests many researchers or health
officers but does not lead to practical public health
action to reduce immediate hazard or risk. Thus, the
surveillance tool as a public health action may be fur-
ther refined and solidified” [6].
One particularly prickly question that continues to
defy agreement concerns the boundaries between sur-
veillance and research. Langmuir cautioned that “the
actual performance of the research study should be rec-
ognised as a function separate from surveillance” [3].
Stephen Thacker, an epidemiologist with the CDC, fur-
ther pursued the question, pointing to the ambiguous-
ness inherent in the definitions of “disease surveillance”
and “epidemiologic surveillance”, proposing that the ex-
pression “public health surveillance” should be adopted
to distinguish it from “epidemiologic research” [7].
Carlo Petrini
Originalarticlesandreviews
B
The definition of “public health surveillance” adopt-
ed by the WHO in its Resolution WHA58.3 clearly
favours Thacker’s proposal and makes an explicit dis-
tinction between public health surveillance and re-
search activities: “Surveillance means the systematic
ongoing collection, collation and analysis of data for
public health purposes and the timely dissemination
of public health information for assessment and pub-
lic health response as necessary” [8].
This is not the place to compare and contrast dif-
ferent notions of surveillance. From the ethical point
of view, however, it should be noted that:
1)	 generally leads to the adoption of control meas-
ures and public health programmes;
2)	 the boundaries between surveillance, research and
control measures are frequently blurred;
3)	 surveillance programmes comprise more than the
mere collection of data;
4)	 surveillance the approach introduced by Langmuir
and later considerably developed marks the pas-
sage from a notion of surveillance that is restricted
to individuals (i.e. typically contacts who had to be
followed up for signs of disease without restricting
their movements by isolation or quarantine) to a
more modern view of surveillance concerned with
diseases.
THE ETHICAL PROBLEMS POSED
BY PUBLIC HEALTH SURVEILLANCE:
INDIVIDUAL INTERESTS VERSUS
COLLECTIVE INTERESTS
The first two of the above points may have strong
ethical implications. The International Encyclopedia of
Public Health notes first that “a surveillance system,
in principle, does not include the control measures
within its system” and then states that: “A surveil-
lance system is better if it is independent from the
control system, because experience has shown that
on some occasions, disease prevalence was artificial-
ly modified by individuals who were responsible for
control measures and sought to gain seemingly bet-
ter results than what was actually occurring” [6]. This
aspect will be addressed below, in the section that
indicates checklists to assess the ethical acceptability
of public health surveillance programmes.
The fourth point listed above refers to one of the
major ethical problems encountered by public health:
the potential conflict between individual and collec-
tive interests.
The significance of this issue is attested by the fact
that the entry for “Surveillance of disease: overview”
in the International Encyclopedia of Public Health con-
tains a paragraph headed “Ethical and legal aspects
of surveillance” that, while brief, is dedicated chiefly
to this issue rather than to other aspects of public
health surveillance: “Surveillance activities often in-
volve surveillance workers handling communities,
people, and institutions in terms of health hazard
investigation, collection of technical as well as origi-
nally private information, and publication of the col-
lected information. It is important that the purpose
of surveillance should be known or fully explained as
needed to the community or individuals so that the
surveillance teams can obtain needed information
with good cooperation on the part of the commu-
nity or individuals. When it is planned, surveillance
should ensure that individuals’ and agencies’ right to
privacy will not be violated. In some cases, however,
this is not simple, because the right to privacy and
the right to know scientific information conflict” [6].
The possible conflict between individual and collec-
tive interests raises questions concerning the contrast
between clinical ethics and public health ethics.
Clinical ethics and public health ethics:
an evident contrast
Until recently the centuries-old tradition of medical
ethics handed down from Hippocrates revolved main-
ly around the physician-patient relationship, in other
words around a relationship between individuals.
The notion of public health calls for an extension of
this relationship to include the community at large.
As Cicero put it: Ollis salus populi suprema lex esto
(Let the good of the people be the supreme law) [9].
The transition from an individual to a collective ap-
proach calls for a reflection on the ethical principles
involved. Can the criteria typically applied in medi-
cal ethics also be considered valid for public health
ethics?
Some authors claim that there is a profound diver-
gence between public health ethics and clinical eth-
ics: “There is, I suggest, a sharp difference between
the ethics which govern public health compared with
those appropriate for clinical specialties” [10] and
“The ethos of public health and that of civil liberties
are radically distinct” [11].
Others maintain that traditional clinical bioethics
are not only different from public health ethics, but
that they are inapplicable when addressing issues of
public health: “It is thus bioethics cannot serve as a
basis for thinking about the balances required in the
defence of public health. As we commence the pro-
cess of shaping an ethics of public health, it is clear
that bioethics is the wrong place to start” [12].
There is no doubt that frequently “public health
and civil liberties (are) in conflict” [13]. Considera-
tions of public health may necessitate the infringe-
ment of individual rights in order to promote collec-
tive interests, thereby posing a direct challenge to the
criteria that are typically applied in clinical ethics.
We must therefore ask “What are the justifications
for limiting individual liberty in order to promote the
public’s health as a common good?” [14].
The question is especially pertinent in public health
surveillance, where it is often not practicable to ask
for or receive valid informed consent. “Public health
surveillance by necessity occurs without explicit pa-
tient consent” [15], and informed consent is the high-
est expression of the principle of autonomy [16]: to
violate this requirement is to undermine the very
foundations of bioethics.
A solution to all these questions could perhaps be
found by referring to a context that has historically
been especially afflicted by such problems: surveil-
Ethics in public health surveillance
Originalarticlesandreviews
C
lance in the early years of the AIDS epidemic: “In
contemporary public health, no condition has pushed
us to think about how individual rights relate to public
health more than HIV/AIDS” [15]. This wake-up call
was partly triggered by the fact that the emergence
of AIDS in the 1980s coincided with the spread of
increasing awareness of and sensitivity to the issues
surrounding the protection of personal data and the
autonomy of individual decisions in the contexts of
clinical medicine and public health [17]. The enor-
mity of the ethical dilemmas posed by AIDS surveil-
lance induced the United Nations to consider the im-
plications, and a special consultation led to the adop-
tion of the International Guidelines. HIV/AIDS and
Human Rights [18], subsequently updated [19]. This
document states categorically that “Public health in-
terests do not conflict with human rights” [18].
Human rights may thus provide a common ground
between individual and collective interests – and also,
therefore, between clinical bioethics and public health
ethics. Seen in this light, the conflict between bioeth-
ics and public health ethics is perhaps simplistic.
Human rights as a common ground for bioethics
and public health ethics
MK Wynia is one of the authors to highlight the sim-
plistic nature of the contrast between bioethics and
public health ethics and how human rights are a fertile
common ground: “According to the oversimplified view
public health ethics is based entirely on a particular type
of consequentialism; let’s call it “health utilitarianism”.
That is, the proper goal of public-health efforts is to ad-
vance the health of as many people as much as possible.
Correct actions in public health can be determined by
calculating the net health benefits to be gained by an
action. If true, this would imply that individual rights
can matter to public-health ethics only insofar as they
affect health outcomes (…). But the conflicts that arise
when attempting to actually implement this oversimpli-
fied version of public health ethics are stark remind-
ers of its inadequacy for practice (…). (T)here is strong
evidence that attention to human rights is critical to good
community health, as well as individual health” (author’s
italics) [20].
In bioethics, as in public health ethics, attention to
human rights leads to further reflection in a historical
perspective. When Van Rensellaer Potter coined the
term “bioethics” [21, 22] there was still a marked ten-
dency among medical ethicists to adopt a paternalistic
stance on the subject. When viewed within the frame-
work of the noted principles of North American bioeth-
ics initially proposed for trials with human subjects [23]
and later extended to every field of medical ethics [24],
this tendency reveals a certain bias towards the prin-
ciple of beneficence. Around the 1980s a widespread
movement to restore the centrality of individual rights
led to emphasis on the principle of autonomy. Today
there is increased sensitivity to the issues of equity in
health, negotiation in decision-making and wider par-
ticipation that may point to a gradual shift towards the
principle of justice. Against this background the issue of
ethics in public health certainly has a place.
ETHICAL MODELS FOR PUBLIC HEALTH
The issues of ethics in public health can be ap-
proached from various angles. One of the most popu-
lar is utilitarianism [25]. The utilitarian doctrine holds
that the proper course of action is one that produces
the greatest well-being and least suffering for the
greatest number of people [26]. The consequences of
actions are assessed on a cost/benefit basis, making
this a typically consequentialist approach [27].
Some of the major criticisms of utilitarianism are
that: it is inherently unfair, since although the over-
all good is considered, its distribution is not; not all
good can be quantified; there is a risk that the cost/
benefit analysis is based on a comparison between
non-homogeneous values; good intentions do not
make an inherently wrong action either good or just
(in other words, a good outcome could be achieved
through a bad action, which is morally unacceptable).
Attempts have been made to address these flaws by
gradually moving away from the “hard utilitarianism”
proposed by Jeremy Bentham (1748-1832) [28] and
John Stuart Mill (1806-1873) [29] towards forms
of “soft utilitarianism” that seek to incorporate new
criteria such as: respect for individuals, equity, im-
partiality, neutrality. However, these criteria cannot
easily compensate for the intrinsic weaknesses of the
utilitarian approach.
Deontologism favours a contrasting stance [30] that
adopts a typically Kantian view of ethics [31] based on
universal moral values and the noted Kantian impera-
tive: “Act in such a way that you treat humanity (…) as
an end and never merely as a means to an end” [32].
One of the major criticisms of this approach is the
fact that it underestimates the consequences of acts:
moral acts may have harmful outcomes.
Communitarianism holds that we must reject the no-
tion of unvarying universal truths [33]. It differs radi-
cally from deontologism [34], asserting that morality
is a cultural value born of a community’s traditions
[35]. Communities are not seen merely as collections
of juxtaposed individuals but as groups of people who
share values, customs, institutions and interests [36].
The major criticisms directed at this view are its re-
jection of values that are common to the whole com-
munity and the risk that it give rise to a “tyranny of
the majority”, when minority groups are also present
in a community.
Egalitarianism considers equality to be one of hu-
mankind’s fundamental values. One of the authors
who has contributed to analysis of this trend in recent
decades is John Rawls [37, 38], for whom “Justice
is the first virtue of social institutions, as truth is of
systems of thought” [39]. Egalitarianism holds that
every individual should have equal rights and equal
opportunities, regardless of his or her condition [40],
though the achievements of each may differ [41].
According to its critics, this approach risks over-
emphasising the means to the detriment of the end,
while also failing to make proper allowances for indi-
vidual and social peculiarities.
Liberalism gives priority to freedom and autonomy
[42, 43], holding that public authorities should do no
Carlo Petrini
Originalarticlesandreviews
D
more than protect individual rights, without interfering
with free enterprise, and that the State should remain
neutral [44].
Its critics highlight the fact that in some sectors,
including public health, market rules alone are inad-
equate or insufficient.
Contractualism asserts that right decisions are based
on correct procedures and the involvement of all the
parties in decision-making [45]. Emphasis is therefore
placed neither on the motivations nor on the conse-
quences of actions, but on their formal correctness:
decision-making procedures, in other words, should be
regulated a priori and rules should be observed [46].
This approach has drawn criticism on several grounds.
In the first place, by considering only the rules it ne-
glects the fact that some human values should be re-
spected regardless (one could use contractual reasoning
to justify crimes and infringements of human rights).
Additionally, decisions whose validity is based only on
the correctness of the negotiation procedures would ex-
clude all those who for varying reasons are not able to
take part in the negotiations.
Individualism maintains that morals cannot be found-
ed on facts, or on objective or transcendental values,
but only on the autonomous decisions of the individual.
It is thus a form of non-cognitivism, since it holds that
values cannot be known. Anything that is free of con-
straint is thus allowed, provided it does not impair the
freedom of others [47].
Critics argue that the kind of freedom proposed by
individualism is partial, since not everybody is able to
express it. With its emphasis on the principle of toler-
ance and the absence of relevant harm it risks justifying
the survival of the fittest.
Personalism places the person above all else [48], while
differing radically from individualism, since it considers
the person as belonging to humankind. According to the
personalists, the common good is constructed by pro-
moting and valuing the good of individuals. Seen in this
light, the noted principles of North American bioethics
(beneficence, autonomy justice) can be re-proposed as:
the therapeutic principle (care of the person); freedom
linked to responsibility, sociality-solidarity [49].
The critics of personalism point to the differences
between its various forms (ontological, hermeneutic,
relational, etc.).
Table 1 offers a brief summary of the ethical requisites
that each “ism” demands of public health interventions.
CODES AND CHECKLISTS FOR ETHICS
IN PUBLIC HEALTH SURVEILLANCE
Of the several codes of public health ethics that have
been published, the one adopted by the American Pub-
lic Health Association is one of the better known [50].
This and other similar codes of ethics are a useful guide
for the specific case of public health surveillance.
Several experts have, either individually or in groups,
drawn up checklists or guidelines to assess the ethical
acceptability of public health surveillance programmes,
as have numerous institutions. Most of these checklists
take a pragmatic approach and are formulated as op-
erational tools.
Most dedicate ample space to the problem of data
protection and confidentiality. The present article will
instead focus more on other aspects, as the protection
of privacy in the public health setting is already the sub-
ject of a large body of literature [51, 52].
Some of these checklists are summarised below, or
as Tables.
Pounder proposed “Nine principles for assessing
whether privacy is protected in a surveillance society”
[53]: these are shown in Table 2.
The Canadian Institutes of Health Research pro-
posed “A tool for ethical analysis of public health sur-
veillance plans”. This comprises eleven criteria: propor-
tionality, usefulness, transparency, representativeness,
equity, participation, independence, stigmatisation,
privacy, informed consent, understandability [54]: they
are described in Table 3.
Other checklists have been proposed which, while
concerning public health ethics in general rather than
surveillance in particular, are eminently adaptable to as-
sess public health surveillance programmes.
Childress et al. suggested that “Regardless of the ethi-
cal theories taken as reference, the relevant moral con-
siderations should include:
1. producing benefits;
2. avoiding, preventing, and removing harms;
3. producing the maximal balance of benefits over
harms and other costs (often called utility);
4. distributing benefits and burdens fairly (distributive
justice) and ensuring public participation, including the
participation of affected parties (procedural justice);
5. respecting autonomous choices and actions, includ-
ing liberty of action;
6. protecting privacy and confidentiality;
7. keeping promises and commitments;
Table 1
Public health ethics in different cultural models
Public health interventions are ethical if they promote
Well-being through scientifically calculated measures Utilitarianism
A good and virtuous life in a just society Deontologism
Attitudes of brotherhood among members of communities Communitarianism
Equality and fairness among persons of different social backgrounds Egalitarianism
Freedom from disease and premature death Liberalism
Individual freedom and autonomy Individualism
The common good, through the good of the individual, while fostering solidarity Personalism
Ethics in public health surveillance
Originalarticlesandreviews
E
Table 2
Nine principles for assessing whether privacy is protected in a surveillance society (from Pounder [53])
Principle 1
Justification
principle
Information relating to any legislation or policy that involves surveillance (or extension
to an existing surveillance policy) is provided so an assessment can be made to ensure
that the surveillance can be justified in terms of pressing social needs and measurable
outcomes; this information is provided prior to the approval of legislation or policy.
Principle 2 Approval principle
Any surveillance is limited to lawful purposes defined in legislation where such legisla-
tion has been thoroughly scrutinised by a fully informed Parliament and, where appro-
priate, informed public debate has taken place.
Principle 3 Separation principle
Procedures which authorise or legitimise a surveillance activity are separate from pro-
cedures related to the actual surveillance itself; the more invasive the surveillance, the
wider the degree of separation.
Principle 4 Adherence principle
Procedures which authorise a surveillance activity are professionally managed and au-
dited; staff involved in a surveillance activity are fully trained to follow relevant proce-
dures and that such training is assessed if appropriate; any malfeasance in
relation to a surveillance activity can be identified and individuals concerned suitably
punished.
Principle 5 Reporting principle
A regulator shall determine what records, including statistical records, are retained and
maintained concerning a surveillance activity, in order to ensure transparency and ac-
countability to the Regulator, to the public and to Parliament.
Principle 6
Independent
supervision
principle
The system of supervision for a surveillance activity is independent of Government,
well financed, and has effective powers of investigation and can delve into operational
matters.
Principle 7 Privacy principle
Individuals should be granted a right to privacy of personal data which can be enforced
by the data protection commissioner and should possess a much simpler right to object
to the processing of personal data in appropriate circumstances.
Principle 8
Compensation
principle
An individual should obtain compensation if a surveillance activity has caused damage,
distress or detriment that proves to be unjustified.
Principle 9
Unacceptability
principle
If the other principles cannot be complied with in relation to a surveillance activity then
within a reasonable time:
a) the activity ceases; or
b) alternative steps are taken to bring the activity into conformity with the principles; or
c) Parliament or a Parliamentary Committee approves the non-compliance with the
relevant principle.
8. disclosing information as well as speaking honestly
and truthfully (often grouped under transparency);
9. building and maintaining trust” [55].
Another suggestion was offered by Krass, who proposed
a six-step model for public health:
1. what are the public health goals of the proposed pro-
gramme?
2. how effective is the programme in achieving its stated
goals?
3. what are the known or potential burdens of the pro-
gramme?
4. can burdens be minimised? Are there alternative ap-
proaches?
5. is the programme implemented fairly?
6. how can the benefits and burdens of a programme be
fairly balanced? [56].
CONCLUSIONS
The ethical problems posed by public health surveil-
lance have been specifically addressed in numerous stud-
ies in the past, and various factors have led to an increase
in this interest in recent years, including the diffusion of
new and unforeseen epidemics and a greater awareness
of and sensitivity towards the issues involved [57].
The checklists shown above can help to assess the
compatibility of public health surveillance programmes
with ethical principles. One of the major problems
highlighted by these tools is the fact that, given the
virtual impossibility of obtaining informed consent, pro-
grammes for public health surveillance frequently ne-
cessitate an infringement of the principle of autonomy.
Today it is widely accepted that “Overriding individual
autonomy must be justified in terms of the obligation
of public health to improve population health, reduce
inequities, attend to the health of vulnerable and sys-
tematically disadvantaged persons, and prevent harm. In
addition, data elements collected without consent must
represent the minimal necessary interference, lead to ef-
fective public health action, and be maintained securely”
[15].
Returning to Childress and co-authors, they sug-
gest five useful “conditions intended to help determine
whether promoting public health warrants overriding
such values as individual liberty or justice in particular
cases”. These conditions encapsulate the key criteria
referred to in the various checklists. They are: effec-
tiveness; proportionality; necessity; least infringement;
public justification” [55].
In summarising the criteria listed above it may also be
helpful to refer to a proposal formulated by the noted
biolaw expert Lawrence Gostin on the spread of Severe
Acute Respiratory Syndrome (SARS). His concise pro-
posal makes a suitable and practical conclusion: “Coer-
cive measures, which violate individual rights, are ac-
ceptable when:
- the risk to public health is demonstrable;
Carlo Petrini
Originalarticlesandreviews
F
- the intervention is likely to be effective, cost-effective,
not overly invasive, fairly distributed;
- the process for pursuing intervention is just and pub-
licly transparent” [58].
Acknowledgements
This article is drawn from a report delivered by the au-
thor to the “Passi” Workshop (“Ethics in public health
surveillance”) organised by the National noordinating
group of the “Passi” Project on 28th
June 2013: the au-
thor would like to thank the organisers of the Workshop
for encouraging and authorising its publication.
Conflict of interest statement
There are no potential conflicts of interest or any fi-
nancial or personal relationships with other people or
organizations that could inappropriately bias conduct
and findings of this study.
Received on 15 July 2013.
Accepted on 25 July 2013.
Table 3
“A tool for ethical analysis of public health surveillance plans”
according to the Canadian Institutes of Health Research [54]
Proportionality Proportionality refers to the idea that the drawbacks of implementing a particular surveillance plan
(such as problems related to privacy or to participation in a survey) must be offset by its benefits,
which it is hoped will be greater. One of the primary justifications for surveillance is that it informs
decision-making about public health programmes and activities. But this effect is hard to measure.
Also, the number of subjects of surveillance and surveillance indicators continues to grow, which
makes the problem of proportionality ever greater.
Usefulness The question of usefulness has been addressed implicitly above. The ultimate usefulness of a
surveillance plan is the contribution that it makes to public health. The decisions made regard-
ing surveillance plans must therefore have this potential to improve public health.
Transparency Transparency is the attribute that a surveillance plan has when its purposes are explicit.
Representativeness A surveillance plan that is representative is one in which: a) the phenomena
to be placed under surveillance accurately reflect the health determinants and health problems
that are recognised as important, and b) the populations studied are represented equitably.
Equity While representativeness refers to the extent to which a surveillance plan allows all of the sub-
groups in a population to be depicted accurately, equity refers to the need to devote particular
attention to certain of these sub-groups, because certain health problems affect them dispropor-
tionately; in other words, the burden of disease is greater among them.
Participation Participation, by partners at least, if not by the public, is assuming growing importance in the field
of public health. As regards public health surveillance in particular, openness to having partners
help develop surveillance plans is nothing new. It helps to ensure that the data gathered will be
more relevant and will be put to better use. The advantages of having the public or certain sub-
groups within the public participate seem less clear. In some cases, such participation would en-
able some important health concerns to be highlighted. It might also help to prevent some cases
of stigmatisation by gauging the sensitivity of the chosen indicators, especially when the data are
disseminated.
Independence The increased presence of players external to the health system who have the financial capacity
to take action on certain problems can place pressure on the public health authorities who develop
surveillance plans to include subjects and indicators whose importance may not really have been
demonstrated. Special care is advisable in such situations.
Stigmatisation Some indicators, when cross-referenced with social and demographic data that identify certain
vulnerable sub-groups of the population and that are available for fairly small geographic units,
may contribute to the stigmatisation of these sub-groups by reinforcing certain prejudices.
Privacy Privacy is the fundamental concern of surveillance authorities not to disclose information that
could be used to identify individuals, households, or communities, depending on the kinds of char-
acteristics on which data are being disseminated.
Informed consent Medical administrative data are usually anonymised before being put to secondary use for sur-
veillance purposes. But this is not always the case, particularly in projects attempting to monitor
problems of comorbidity and multimorbidity. In such cases, consent to secondary use of data
might pose problems, because it might not be possible to give this consent at the time that the
data are collected.
Understandability Lastly, the data should be disseminated in such as way that they can be understood by the public,
because of course it is with the public’s health that these data deal.
Ethics in public health surveillance
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Ethics in public health surveillance

  • 1. Carlo Petrini Address for correspondence: Carlo Petrini. Unità di Bioetica, Presidenza, Istituto Superiore di Sanità, Via Giano della Bella 34, 00162 Rome, Italy. E-mail carlo.petrini@iss.it. Abstract Public health programmes pose some very important ethical problems. One of the most pressing is the possible conflict between individual interests (and rights) and collective interests, which becomes particularly important in the public health surveillance setting. The present article first looks at the definitions of “public health surveillance” in a histori- cal context and then identifies the key ethical problems that are raised. These reveal the differences – and sometimes deviations – between the bioethical issues typically encoun- tered in a clinical setting and those that prevail in a public health context. Human rights are suggested as a possible common ground between the two. The article then draws on the specialised literature to indicate tools and checklists to help evaluate the ethical ac- ceptability of public health surveillance programmes. It concludes with a description of the key criteria underlying these tools and checklists. Ethics in public health surveillance Unità di Bioetica, Presidenza, Istituto Superiore di Sanità, Rome, Italy Ann Ist Super Sanità 2013 | Vol. 49, No. 4: 000-000 DOI Key words • autonomy • bioethics • informed consent • public health surveillance Originalarticlesandreviews A HISTORICAL NOTES AND DEFINITIONS The history of public health surveillance can be traced back as far as the Renaissance, confirming that its importance was recognised long before recent discoveries in the field of infectious diseases and the elaboration of the diagnostic tools available to today’s epidemiologists [1]. In 1938 William Farr convincingly described the importance of public health surveillance with the help of registers: “Half the life is passed in infancy, sick- ness and dependent helplessness. In exhibiting the high mortality, the diseases by which it is occasioned and the exciting causes of disease, the abstracts of the Registers will prove that while a part of the sickness is inevitable and part may be expected to disappear by progressive social amelioration a considerable pro- portion may be suppressed by the general adoption of hygienic measures (...). Morbidity registration will be an invaluable contribution to therapeutics, as well as to hygiene, for it will enable the therapeutists to determine the duration and fatality of all forms of disease (…). Illusion will be dispelled, quackery (…) suppressed, a science of therapeutics created, suffer- ing diminished, life shielded from many dangers” [2]. Around the middle of the last century, when infec- tious diseases were the most pressing problem for public health authorities worldwide, Alexander Lang- muir of the Centers for Disease Control and Preven- tion (CDC) drew up a programme for the system- atic surveillance of infectious diseases. In 1963 he defined surveillance as “the continued watchfulness over the distribution and trends of incidence through the systematic collection, consolidation and evalu- ation of morbidity and mortality reports and other relevant data. Intrinsic in the concept is the regular dissemination of the basic data and interpretations to all who have contributed and to all others who need to know” [3]. The basic elements underlying the no- tion of “surveillance” proposed by Langmuir [3] and later re-elaborated [4] are: 1) systematic and active collection of pertinent data on target disease(s); 2) assessment and practical reporting of these data, and 3) the timely dissemination of reports to individuals responsible for the formulation of action plans. A few years later Karel Raska of the Communicable Disease Division at the World Health Organisation (WHO) extended Langmuir’s definition to include epidemiological research in surveillance activities [5]. Half a century later the debate as to where the boundaries of public health surveillance should be drawn is still unresolved: “In the area of public health practice, we may need to rethink the boundary of surveillance systems. It may be wise not to expand it to a broad investigation or epidemiological research, which certainly interests many researchers or health officers but does not lead to practical public health action to reduce immediate hazard or risk. Thus, the surveillance tool as a public health action may be fur- ther refined and solidified” [6]. One particularly prickly question that continues to defy agreement concerns the boundaries between sur- veillance and research. Langmuir cautioned that “the actual performance of the research study should be rec- ognised as a function separate from surveillance” [3]. Stephen Thacker, an epidemiologist with the CDC, fur- ther pursued the question, pointing to the ambiguous- ness inherent in the definitions of “disease surveillance” and “epidemiologic surveillance”, proposing that the ex- pression “public health surveillance” should be adopted to distinguish it from “epidemiologic research” [7].
  • 2. Carlo Petrini Originalarticlesandreviews B The definition of “public health surveillance” adopt- ed by the WHO in its Resolution WHA58.3 clearly favours Thacker’s proposal and makes an explicit dis- tinction between public health surveillance and re- search activities: “Surveillance means the systematic ongoing collection, collation and analysis of data for public health purposes and the timely dissemination of public health information for assessment and pub- lic health response as necessary” [8]. This is not the place to compare and contrast dif- ferent notions of surveillance. From the ethical point of view, however, it should be noted that: 1) generally leads to the adoption of control meas- ures and public health programmes; 2) the boundaries between surveillance, research and control measures are frequently blurred; 3) surveillance programmes comprise more than the mere collection of data; 4) surveillance the approach introduced by Langmuir and later considerably developed marks the pas- sage from a notion of surveillance that is restricted to individuals (i.e. typically contacts who had to be followed up for signs of disease without restricting their movements by isolation or quarantine) to a more modern view of surveillance concerned with diseases. THE ETHICAL PROBLEMS POSED BY PUBLIC HEALTH SURVEILLANCE: INDIVIDUAL INTERESTS VERSUS COLLECTIVE INTERESTS The first two of the above points may have strong ethical implications. The International Encyclopedia of Public Health notes first that “a surveillance system, in principle, does not include the control measures within its system” and then states that: “A surveil- lance system is better if it is independent from the control system, because experience has shown that on some occasions, disease prevalence was artificial- ly modified by individuals who were responsible for control measures and sought to gain seemingly bet- ter results than what was actually occurring” [6]. This aspect will be addressed below, in the section that indicates checklists to assess the ethical acceptability of public health surveillance programmes. The fourth point listed above refers to one of the major ethical problems encountered by public health: the potential conflict between individual and collec- tive interests. The significance of this issue is attested by the fact that the entry for “Surveillance of disease: overview” in the International Encyclopedia of Public Health con- tains a paragraph headed “Ethical and legal aspects of surveillance” that, while brief, is dedicated chiefly to this issue rather than to other aspects of public health surveillance: “Surveillance activities often in- volve surveillance workers handling communities, people, and institutions in terms of health hazard investigation, collection of technical as well as origi- nally private information, and publication of the col- lected information. It is important that the purpose of surveillance should be known or fully explained as needed to the community or individuals so that the surveillance teams can obtain needed information with good cooperation on the part of the commu- nity or individuals. When it is planned, surveillance should ensure that individuals’ and agencies’ right to privacy will not be violated. In some cases, however, this is not simple, because the right to privacy and the right to know scientific information conflict” [6]. The possible conflict between individual and collec- tive interests raises questions concerning the contrast between clinical ethics and public health ethics. Clinical ethics and public health ethics: an evident contrast Until recently the centuries-old tradition of medical ethics handed down from Hippocrates revolved main- ly around the physician-patient relationship, in other words around a relationship between individuals. The notion of public health calls for an extension of this relationship to include the community at large. As Cicero put it: Ollis salus populi suprema lex esto (Let the good of the people be the supreme law) [9]. The transition from an individual to a collective ap- proach calls for a reflection on the ethical principles involved. Can the criteria typically applied in medi- cal ethics also be considered valid for public health ethics? Some authors claim that there is a profound diver- gence between public health ethics and clinical eth- ics: “There is, I suggest, a sharp difference between the ethics which govern public health compared with those appropriate for clinical specialties” [10] and “The ethos of public health and that of civil liberties are radically distinct” [11]. Others maintain that traditional clinical bioethics are not only different from public health ethics, but that they are inapplicable when addressing issues of public health: “It is thus bioethics cannot serve as a basis for thinking about the balances required in the defence of public health. As we commence the pro- cess of shaping an ethics of public health, it is clear that bioethics is the wrong place to start” [12]. There is no doubt that frequently “public health and civil liberties (are) in conflict” [13]. Considera- tions of public health may necessitate the infringe- ment of individual rights in order to promote collec- tive interests, thereby posing a direct challenge to the criteria that are typically applied in clinical ethics. We must therefore ask “What are the justifications for limiting individual liberty in order to promote the public’s health as a common good?” [14]. The question is especially pertinent in public health surveillance, where it is often not practicable to ask for or receive valid informed consent. “Public health surveillance by necessity occurs without explicit pa- tient consent” [15], and informed consent is the high- est expression of the principle of autonomy [16]: to violate this requirement is to undermine the very foundations of bioethics. A solution to all these questions could perhaps be found by referring to a context that has historically been especially afflicted by such problems: surveil-
  • 3. Ethics in public health surveillance Originalarticlesandreviews C lance in the early years of the AIDS epidemic: “In contemporary public health, no condition has pushed us to think about how individual rights relate to public health more than HIV/AIDS” [15]. This wake-up call was partly triggered by the fact that the emergence of AIDS in the 1980s coincided with the spread of increasing awareness of and sensitivity to the issues surrounding the protection of personal data and the autonomy of individual decisions in the contexts of clinical medicine and public health [17]. The enor- mity of the ethical dilemmas posed by AIDS surveil- lance induced the United Nations to consider the im- plications, and a special consultation led to the adop- tion of the International Guidelines. HIV/AIDS and Human Rights [18], subsequently updated [19]. This document states categorically that “Public health in- terests do not conflict with human rights” [18]. Human rights may thus provide a common ground between individual and collective interests – and also, therefore, between clinical bioethics and public health ethics. Seen in this light, the conflict between bioeth- ics and public health ethics is perhaps simplistic. Human rights as a common ground for bioethics and public health ethics MK Wynia is one of the authors to highlight the sim- plistic nature of the contrast between bioethics and public health ethics and how human rights are a fertile common ground: “According to the oversimplified view public health ethics is based entirely on a particular type of consequentialism; let’s call it “health utilitarianism”. That is, the proper goal of public-health efforts is to ad- vance the health of as many people as much as possible. Correct actions in public health can be determined by calculating the net health benefits to be gained by an action. If true, this would imply that individual rights can matter to public-health ethics only insofar as they affect health outcomes (…). But the conflicts that arise when attempting to actually implement this oversimpli- fied version of public health ethics are stark remind- ers of its inadequacy for practice (…). (T)here is strong evidence that attention to human rights is critical to good community health, as well as individual health” (author’s italics) [20]. In bioethics, as in public health ethics, attention to human rights leads to further reflection in a historical perspective. When Van Rensellaer Potter coined the term “bioethics” [21, 22] there was still a marked ten- dency among medical ethicists to adopt a paternalistic stance on the subject. When viewed within the frame- work of the noted principles of North American bioeth- ics initially proposed for trials with human subjects [23] and later extended to every field of medical ethics [24], this tendency reveals a certain bias towards the prin- ciple of beneficence. Around the 1980s a widespread movement to restore the centrality of individual rights led to emphasis on the principle of autonomy. Today there is increased sensitivity to the issues of equity in health, negotiation in decision-making and wider par- ticipation that may point to a gradual shift towards the principle of justice. Against this background the issue of ethics in public health certainly has a place. ETHICAL MODELS FOR PUBLIC HEALTH The issues of ethics in public health can be ap- proached from various angles. One of the most popu- lar is utilitarianism [25]. The utilitarian doctrine holds that the proper course of action is one that produces the greatest well-being and least suffering for the greatest number of people [26]. The consequences of actions are assessed on a cost/benefit basis, making this a typically consequentialist approach [27]. Some of the major criticisms of utilitarianism are that: it is inherently unfair, since although the over- all good is considered, its distribution is not; not all good can be quantified; there is a risk that the cost/ benefit analysis is based on a comparison between non-homogeneous values; good intentions do not make an inherently wrong action either good or just (in other words, a good outcome could be achieved through a bad action, which is morally unacceptable). Attempts have been made to address these flaws by gradually moving away from the “hard utilitarianism” proposed by Jeremy Bentham (1748-1832) [28] and John Stuart Mill (1806-1873) [29] towards forms of “soft utilitarianism” that seek to incorporate new criteria such as: respect for individuals, equity, im- partiality, neutrality. However, these criteria cannot easily compensate for the intrinsic weaknesses of the utilitarian approach. Deontologism favours a contrasting stance [30] that adopts a typically Kantian view of ethics [31] based on universal moral values and the noted Kantian impera- tive: “Act in such a way that you treat humanity (…) as an end and never merely as a means to an end” [32]. One of the major criticisms of this approach is the fact that it underestimates the consequences of acts: moral acts may have harmful outcomes. Communitarianism holds that we must reject the no- tion of unvarying universal truths [33]. It differs radi- cally from deontologism [34], asserting that morality is a cultural value born of a community’s traditions [35]. Communities are not seen merely as collections of juxtaposed individuals but as groups of people who share values, customs, institutions and interests [36]. The major criticisms directed at this view are its re- jection of values that are common to the whole com- munity and the risk that it give rise to a “tyranny of the majority”, when minority groups are also present in a community. Egalitarianism considers equality to be one of hu- mankind’s fundamental values. One of the authors who has contributed to analysis of this trend in recent decades is John Rawls [37, 38], for whom “Justice is the first virtue of social institutions, as truth is of systems of thought” [39]. Egalitarianism holds that every individual should have equal rights and equal opportunities, regardless of his or her condition [40], though the achievements of each may differ [41]. According to its critics, this approach risks over- emphasising the means to the detriment of the end, while also failing to make proper allowances for indi- vidual and social peculiarities. Liberalism gives priority to freedom and autonomy [42, 43], holding that public authorities should do no
  • 4. Carlo Petrini Originalarticlesandreviews D more than protect individual rights, without interfering with free enterprise, and that the State should remain neutral [44]. Its critics highlight the fact that in some sectors, including public health, market rules alone are inad- equate or insufficient. Contractualism asserts that right decisions are based on correct procedures and the involvement of all the parties in decision-making [45]. Emphasis is therefore placed neither on the motivations nor on the conse- quences of actions, but on their formal correctness: decision-making procedures, in other words, should be regulated a priori and rules should be observed [46]. This approach has drawn criticism on several grounds. In the first place, by considering only the rules it ne- glects the fact that some human values should be re- spected regardless (one could use contractual reasoning to justify crimes and infringements of human rights). Additionally, decisions whose validity is based only on the correctness of the negotiation procedures would ex- clude all those who for varying reasons are not able to take part in the negotiations. Individualism maintains that morals cannot be found- ed on facts, or on objective or transcendental values, but only on the autonomous decisions of the individual. It is thus a form of non-cognitivism, since it holds that values cannot be known. Anything that is free of con- straint is thus allowed, provided it does not impair the freedom of others [47]. Critics argue that the kind of freedom proposed by individualism is partial, since not everybody is able to express it. With its emphasis on the principle of toler- ance and the absence of relevant harm it risks justifying the survival of the fittest. Personalism places the person above all else [48], while differing radically from individualism, since it considers the person as belonging to humankind. According to the personalists, the common good is constructed by pro- moting and valuing the good of individuals. Seen in this light, the noted principles of North American bioethics (beneficence, autonomy justice) can be re-proposed as: the therapeutic principle (care of the person); freedom linked to responsibility, sociality-solidarity [49]. The critics of personalism point to the differences between its various forms (ontological, hermeneutic, relational, etc.). Table 1 offers a brief summary of the ethical requisites that each “ism” demands of public health interventions. CODES AND CHECKLISTS FOR ETHICS IN PUBLIC HEALTH SURVEILLANCE Of the several codes of public health ethics that have been published, the one adopted by the American Pub- lic Health Association is one of the better known [50]. This and other similar codes of ethics are a useful guide for the specific case of public health surveillance. Several experts have, either individually or in groups, drawn up checklists or guidelines to assess the ethical acceptability of public health surveillance programmes, as have numerous institutions. Most of these checklists take a pragmatic approach and are formulated as op- erational tools. Most dedicate ample space to the problem of data protection and confidentiality. The present article will instead focus more on other aspects, as the protection of privacy in the public health setting is already the sub- ject of a large body of literature [51, 52]. Some of these checklists are summarised below, or as Tables. Pounder proposed “Nine principles for assessing whether privacy is protected in a surveillance society” [53]: these are shown in Table 2. The Canadian Institutes of Health Research pro- posed “A tool for ethical analysis of public health sur- veillance plans”. This comprises eleven criteria: propor- tionality, usefulness, transparency, representativeness, equity, participation, independence, stigmatisation, privacy, informed consent, understandability [54]: they are described in Table 3. Other checklists have been proposed which, while concerning public health ethics in general rather than surveillance in particular, are eminently adaptable to as- sess public health surveillance programmes. Childress et al. suggested that “Regardless of the ethi- cal theories taken as reference, the relevant moral con- siderations should include: 1. producing benefits; 2. avoiding, preventing, and removing harms; 3. producing the maximal balance of benefits over harms and other costs (often called utility); 4. distributing benefits and burdens fairly (distributive justice) and ensuring public participation, including the participation of affected parties (procedural justice); 5. respecting autonomous choices and actions, includ- ing liberty of action; 6. protecting privacy and confidentiality; 7. keeping promises and commitments; Table 1 Public health ethics in different cultural models Public health interventions are ethical if they promote Well-being through scientifically calculated measures Utilitarianism A good and virtuous life in a just society Deontologism Attitudes of brotherhood among members of communities Communitarianism Equality and fairness among persons of different social backgrounds Egalitarianism Freedom from disease and premature death Liberalism Individual freedom and autonomy Individualism The common good, through the good of the individual, while fostering solidarity Personalism
  • 5. Ethics in public health surveillance Originalarticlesandreviews E Table 2 Nine principles for assessing whether privacy is protected in a surveillance society (from Pounder [53]) Principle 1 Justification principle Information relating to any legislation or policy that involves surveillance (or extension to an existing surveillance policy) is provided so an assessment can be made to ensure that the surveillance can be justified in terms of pressing social needs and measurable outcomes; this information is provided prior to the approval of legislation or policy. Principle 2 Approval principle Any surveillance is limited to lawful purposes defined in legislation where such legisla- tion has been thoroughly scrutinised by a fully informed Parliament and, where appro- priate, informed public debate has taken place. Principle 3 Separation principle Procedures which authorise or legitimise a surveillance activity are separate from pro- cedures related to the actual surveillance itself; the more invasive the surveillance, the wider the degree of separation. Principle 4 Adherence principle Procedures which authorise a surveillance activity are professionally managed and au- dited; staff involved in a surveillance activity are fully trained to follow relevant proce- dures and that such training is assessed if appropriate; any malfeasance in relation to a surveillance activity can be identified and individuals concerned suitably punished. Principle 5 Reporting principle A regulator shall determine what records, including statistical records, are retained and maintained concerning a surveillance activity, in order to ensure transparency and ac- countability to the Regulator, to the public and to Parliament. Principle 6 Independent supervision principle The system of supervision for a surveillance activity is independent of Government, well financed, and has effective powers of investigation and can delve into operational matters. Principle 7 Privacy principle Individuals should be granted a right to privacy of personal data which can be enforced by the data protection commissioner and should possess a much simpler right to object to the processing of personal data in appropriate circumstances. Principle 8 Compensation principle An individual should obtain compensation if a surveillance activity has caused damage, distress or detriment that proves to be unjustified. Principle 9 Unacceptability principle If the other principles cannot be complied with in relation to a surveillance activity then within a reasonable time: a) the activity ceases; or b) alternative steps are taken to bring the activity into conformity with the principles; or c) Parliament or a Parliamentary Committee approves the non-compliance with the relevant principle. 8. disclosing information as well as speaking honestly and truthfully (often grouped under transparency); 9. building and maintaining trust” [55]. Another suggestion was offered by Krass, who proposed a six-step model for public health: 1. what are the public health goals of the proposed pro- gramme? 2. how effective is the programme in achieving its stated goals? 3. what are the known or potential burdens of the pro- gramme? 4. can burdens be minimised? Are there alternative ap- proaches? 5. is the programme implemented fairly? 6. how can the benefits and burdens of a programme be fairly balanced? [56]. CONCLUSIONS The ethical problems posed by public health surveil- lance have been specifically addressed in numerous stud- ies in the past, and various factors have led to an increase in this interest in recent years, including the diffusion of new and unforeseen epidemics and a greater awareness of and sensitivity towards the issues involved [57]. The checklists shown above can help to assess the compatibility of public health surveillance programmes with ethical principles. One of the major problems highlighted by these tools is the fact that, given the virtual impossibility of obtaining informed consent, pro- grammes for public health surveillance frequently ne- cessitate an infringement of the principle of autonomy. Today it is widely accepted that “Overriding individual autonomy must be justified in terms of the obligation of public health to improve population health, reduce inequities, attend to the health of vulnerable and sys- tematically disadvantaged persons, and prevent harm. In addition, data elements collected without consent must represent the minimal necessary interference, lead to ef- fective public health action, and be maintained securely” [15]. Returning to Childress and co-authors, they sug- gest five useful “conditions intended to help determine whether promoting public health warrants overriding such values as individual liberty or justice in particular cases”. These conditions encapsulate the key criteria referred to in the various checklists. They are: effec- tiveness; proportionality; necessity; least infringement; public justification” [55]. In summarising the criteria listed above it may also be helpful to refer to a proposal formulated by the noted biolaw expert Lawrence Gostin on the spread of Severe Acute Respiratory Syndrome (SARS). His concise pro- posal makes a suitable and practical conclusion: “Coer- cive measures, which violate individual rights, are ac- ceptable when: - the risk to public health is demonstrable;
  • 6. Carlo Petrini Originalarticlesandreviews F - the intervention is likely to be effective, cost-effective, not overly invasive, fairly distributed; - the process for pursuing intervention is just and pub- licly transparent” [58]. Acknowledgements This article is drawn from a report delivered by the au- thor to the “Passi” Workshop (“Ethics in public health surveillance”) organised by the National noordinating group of the “Passi” Project on 28th June 2013: the au- thor would like to thank the organisers of the Workshop for encouraging and authorising its publication. Conflict of interest statement There are no potential conflicts of interest or any fi- nancial or personal relationships with other people or organizations that could inappropriately bias conduct and findings of this study. Received on 15 July 2013. Accepted on 25 July 2013. Table 3 “A tool for ethical analysis of public health surveillance plans” according to the Canadian Institutes of Health Research [54] Proportionality Proportionality refers to the idea that the drawbacks of implementing a particular surveillance plan (such as problems related to privacy or to participation in a survey) must be offset by its benefits, which it is hoped will be greater. One of the primary justifications for surveillance is that it informs decision-making about public health programmes and activities. But this effect is hard to measure. Also, the number of subjects of surveillance and surveillance indicators continues to grow, which makes the problem of proportionality ever greater. Usefulness The question of usefulness has been addressed implicitly above. The ultimate usefulness of a surveillance plan is the contribution that it makes to public health. The decisions made regard- ing surveillance plans must therefore have this potential to improve public health. Transparency Transparency is the attribute that a surveillance plan has when its purposes are explicit. Representativeness A surveillance plan that is representative is one in which: a) the phenomena to be placed under surveillance accurately reflect the health determinants and health problems that are recognised as important, and b) the populations studied are represented equitably. Equity While representativeness refers to the extent to which a surveillance plan allows all of the sub- groups in a population to be depicted accurately, equity refers to the need to devote particular attention to certain of these sub-groups, because certain health problems affect them dispropor- tionately; in other words, the burden of disease is greater among them. Participation Participation, by partners at least, if not by the public, is assuming growing importance in the field of public health. As regards public health surveillance in particular, openness to having partners help develop surveillance plans is nothing new. It helps to ensure that the data gathered will be more relevant and will be put to better use. The advantages of having the public or certain sub- groups within the public participate seem less clear. In some cases, such participation would en- able some important health concerns to be highlighted. It might also help to prevent some cases of stigmatisation by gauging the sensitivity of the chosen indicators, especially when the data are disseminated. Independence The increased presence of players external to the health system who have the financial capacity to take action on certain problems can place pressure on the public health authorities who develop surveillance plans to include subjects and indicators whose importance may not really have been demonstrated. Special care is advisable in such situations. Stigmatisation Some indicators, when cross-referenced with social and demographic data that identify certain vulnerable sub-groups of the population and that are available for fairly small geographic units, may contribute to the stigmatisation of these sub-groups by reinforcing certain prejudices. Privacy Privacy is the fundamental concern of surveillance authorities not to disclose information that could be used to identify individuals, households, or communities, depending on the kinds of char- acteristics on which data are being disseminated. Informed consent Medical administrative data are usually anonymised before being put to secondary use for sur- veillance purposes. But this is not always the case, particularly in projects attempting to monitor problems of comorbidity and multimorbidity. In such cases, consent to secondary use of data might pose problems, because it might not be possible to give this consent at the time that the data are collected. Understandability Lastly, the data should be disseminated in such as way that they can be understood by the public, because of course it is with the public’s health that these data deal.
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