This presentation was delivered to members of IPPOSI (www.ipposi.ie) on October 2nd 2015. It concerns a draft Privacy Impact Assessment for Individual Health Identifiers in Ireland.

1. Delivering eHealth Ireland | Office of the Chief Information Officer
THE INDIVIDUAL HEALTH
IDENTIFIER
Clare Sanderson
IG Solutions, Liverpool
1

2. Delivering eHealth Ireland | Office of the Chief Information Officer
Agenda
 1. Presentation:
 Background to the Individual Health Identifier
 Explanation of what a Privacy Impact Assessment is
 Explain what we have done
 Proposals for the public consultation
 2. Discussion with the group
 How we will present the findings
 Questions we will ask

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Health Identifier Act 2014
 A unique number (an Individual Health Identifier or IHI) will be
assigned to each person that has used, is using or may use a
health or social care service in Ireland
 A unique number (a Health Service Provider Identifier or
HSPI) will be assigned to any practitioner or organisation who
provides a health or social care service in Ireland
 NOTE - We are only concerned with the IHI at this stage.

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Health Identifier Act 2014 (continued)
 A register of IHIs and related personal information will be
established and maintained.
 The register will not contain any clinical information
 The Minister for Health will agree who can access the register
and process the personal data it holds
 The Minister for Health can delegate functions to the Health
Service Executive

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Why do you need an IHI?
Your IHI will help:
 Health service providers to identify you uniquely
 To improve patient safety
 Your records in different healthcare providers to be
accurately associated with you
 To share information between those who are looking
after you for example on referral letters sent from a
public hospital to a private GP
 The electronic transfer of your health information,
which results in faster care for you.

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Some facts about the IHI
 Your IHI will look like this:
5934-014 893-485-897-3-2
 Your IHI doesn’t contain any personal information about you
(such as your date of birth)
 Your IHI will be allocated at random
 Your IHI will never be allocated to anyone else, even after you
die

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What information is held on the IHI register?
 The IHI register contains demographic information,
(no clinical information):
 (a) surname;
 (b) forename;
 (c) date of birth;
 (d) place of birth;
 (e) sex;
 (f) all former surnames;
 (g) mother’s surname at birth;
 (h) address;
 (i) nationality;
 (j) personal public service number PPSN (if any)
 (k) date of death in the case of a deceased individual;
 (l) signature
 (m) photograph

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What is a Privacy Impact Assessment?
 A PIA is an approach that helps us to make
sure
 we have safeguards in place to protect your
information
 we abide by data protection laws
 A PIA is recommended by the Data Protection
Commissioner and the Health Information and
Quality Authority for projects like this.

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What does A PIA involve?
 Discussions with a range of stakeholders
(including the public) about:
 The design of the IHI project
 The benefits of having an IHI
 The risks to your privacy
 Safeguards to mitigate the risks which will either:
 Reduce the possibility that the risk will occur
 Reduce the impact if it does occur
 Identification of those responsible for implementing
the safeguards

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Public consultation
 The consultation is part of the stakeholder
engagement
 It will allow the public to provide their views

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Why do we want your help?
 This is a complex topic:
 Use of plain English!
 Include a short summary at the front
 BUT
 How can we get the technical aspects over in an
understandable way?
 Will our questions get the feedback we are looking
for?

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Discussion Topics
 How we will present the key components of
the PIA in the consultation document:
1. Technical descriptions
2. Benefits
3. Privacy Risks & Safeguards

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1. Technical Descriptions – the issue
 The Legal Basis for the IHI
 What a Privacy Impact Assessment is
 How the IHI register will be created and used

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1. Technical Descriptions - solution
Options:
 Include details in the main body of the
consultation document
 Summarise in body of the document and
include details as appendices to the document
 Summarise in the FAQs
 Other?

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2. Benefits – the issue
 Benefits apply to you, your health and social care providers
and your GP.
 Should we state them all or just yours?
 Should we also provide examples / scenarios?

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Stating the benefits
16
 Should we add…..
 For example, your GP sends a letter to Beaumont hospital
referring you for an outpatient appointment but the hospital
has two patients with your name and date of birth. If your IHI
is included in the letter this will help to ensure that YOUR
medical records are available at outpatient clinic.

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The question we will ask
 Are all the benefits clear to you? Y/N
 Should we add NOT SURE?
 Are there any other benefits we should include?

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3 Privacy Risks & Safeguards – the issue
Privacy Issue Prob’y Impact Risk
Score
Proposed mitigation actions or controls Prob’y Impact Risk
Score
Establishment of the
National Register
creates a risk that
personal confidential
information may be
accessed illegally
(e.g. identity theft,
sold or otherwise
misused by
commercial
organisations)
4 5 20 Responsibility for the technical solution and physical controls lies with the Office
of the Chief Information Officer
The health identifiers operator implements appropriate security controls around
the National Register that meet current best practice for data protection
(including for example data is encrypted at all stages).
The health identifiers operator has safe and effective recruitment practices in
place.
The health identifiers operator seeks to prosecute those (both internal staff and
external organisations) that knowingly access or process the Individual Health
Identifier data inappropriately as provided for within the provisions of the Act.
The National Register will only be held on servers physically located within Ireland
Implement the HIQA IG standards
1 5 5

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How the scoring works
19
Likelihood
Impact Rare
1
Unlikely
2
Possible
3
Likely
4
Highly Likely
5
Negligible - 1 1 2 3 4 5
Minor - 2 2 4 6 8 10
Moderate - 3 3 6 9 12 15
Major - 4 4 8 12 16 20
Critical - 5 5 10 15 20 25
LOW (1-7) MEDIUM (8-14) HIGH (15-25)

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3 Privacy Risks & Safeguards – the issue
Privacy Issue Prob’y Impact Risk
Score
Proposed mitigation actions or controls Prob’y Impact Risk
Score
Establishment of the
National Register
creates a risk that
personal confidential
information may be
accessed illegally
(e.g. identity theft,
sold or otherwise
misused by
commercial
organisations)
4 5 20 Responsibility for the technical solution and physical controls lies with the Office
of the Chief Information Officer
The health identifiers operator implements appropriate security controls around
the National Register that meet current best practice for data protection
(including for example data is encrypted at all stages).
The health identifiers operator has safe and effective recruitment practices in
place.
The health identifiers operator seeks to prosecute those (both internal staff and
external organisations) that knowingly access or process the Individual Health
Identifier data inappropriately as provided for within the provisions of the Act.
The National Register will only be held on servers physically located within Ireland
Implement the HIQA IG standards
1 5 5

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3. Privacy Risks & Safeguards – the solution?
21
Risk Prob’y Impact Risk
Score
Proposed mitigation actions or controls Prob’y Impact Risk
Score
Children attending St
Ignatius Primacy
School have to cross
a busy road and are
at risk of being run
over.
4 5 20 Reduce the speed limit for cars outside the school to 20 mph
Improve street lighting outside the school
Add road signs to warn drivers that there is a school in 100 yards
Prevent parents from parking on the road to drop children off
Provide a school road crossing warden at start and end of school day
1 4 4

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The question we will ask
 Have we identified all the privacy risks? Y/N
 Should we add NOT SURE?
 Are there any other privacy risks we should include?

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The question we will ask
Have we identified sufficient safeguards to supplement
the HIQA IG standards? Y/N
 Should we add NOT SURE?
 Are there any other safeguards we should include?

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The final question we will ask
 Is there anything else you wish to add? Y/N

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Public consultation
 We will engage with patient advocacy groups
 We will include FAQs – copies are at the back
 We would appreciate your feedback to:
questions@ehealthireland.ie

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Thank you for taking part today