1. User account
- Healthcare professionals would require an user account in Electronic Health Record Sharing System ("eHRSS" or "the System") created by the healthcare provider(s) they are working with for accessing and using ofeHRSS. To access eHRSS via different healthcare providers, healthcare professionals need to maintain their separate user accounts under different providers.
- Healthcare professionals should provide updated professional registration information to electronic health record (eHR) Office for verification.
2. Update records for eHR sharing
- Healthcare professionals should keep clear, accurate and updated clinical records of their healthcare recipient and share to eHRSS in a timely manner.
- Healthcare professionals should comply with PDPO (Cap. 486) while maintaining and sharing of the healthcare recipient's health records to eHRSS and make sure the information is accurate and not excessive.
- Healthcare professionals should exercise reasonable care in handling personal information related to other individuals in their healthcare recipients' records. Personal information of individual(s) other than the healthcare recipient in their healthcare recipients' clinical records should not be collected and shared to eHRSS unless it is deem necessary and consent from the concerned other individual has been obtained. Personal information may include name, contact information, date of birth and identity document number of other individuals (e.g. family members).
- Healthcare professionals should advise healthcare recipients to approach the healthcare providers who provide the corresponding health information to eHRSS to consider data correction if they genuinely doubt the correctness of information in their eHR. It is advisable to document such observation in their healthcare recipients' records.
- Healthcare professionals should have responsibility to assist their respective healthcare providers to deal with data correction request for alleged incorrect information in their healthcare recipients' clinical records in a manner and within a time frame as specified under Personal Data (Privacy) Ordinance (Cap. 486) (PDPO) and to provide an updated record to eHRSS , if that information has previously been shared to eHRSS.
- Healthcare professionals should exercise careful judgment for accepting or refusing a data correction request from their healthcare recipients. If they are not satisfied that the information to which the request relates is inaccurate and they should inform healthcare recipients or the requesters the decision and reasons of refusal in accordance with PDPO (Cap. 486).
- Healthcare professionals should document the reasons for refusal for data correction request in their healthcare recipient's records in accordance with PDPO (Cap. 486) and established Data Correction Request (DCR) procedures defined by eHR Office.
3. Points to note before accessing a healthcare recipient's eHR
- Healthcare professionals should ensure their access to a healthcare recipient's eHR is authorised.
- Healthcare professionals have the responsibility to exercise judgement on clinical grounds whether and how much information from a healthcare recipient's eHR should be accessed.
- Healthcare professionals should have the autonomy and professional judgment to interpret the information in eHRSS.
- Healthcare professionals should only access eHR of healthcare recipients with their expressed and informed sharing consent and there is a need-to-know about the healthcare recipients' health conditions according to their roles of providing healthcare to the healthcare recipient.
- Healthcare professionals should be aware that the healthcare recipients will receive a notification from eHRSS for any access to their eHR.
- Healthcare professionals should be aware that, for any healthcare recipient who is incapable of giving sharing consent to healthcare providers for eHR access, the healthcare professionals may make emergency access to the eHR of the healthcare recipient if that is of paramount importance for provisions of emergency treatment to the healthcare recipient and subject to the relevant healthcare provider's own internal rules, if applicable. Healthcare professionals are advised to document such access in their healthcare recipients' record and the justification in eHRSS and should be aware that such emergency access is subject to audit.
4. Points to note when viewing and using eHR
- Healthcare professionals should interpret information from eHRSS with care as it may not be updated and complete. They should judge the need to verify with other sources of information, and ideally, with the healthcare recipient, especially when in doubt or inconsistency is noted.
- Healthcare professionals should not regard eHR as a substitute for personal communication with their healthcare recipients and other healthcare professionals.
- Healthcare professionals should document relevant and important decisions and discussions, if applicable, with their healthcare recipients regarding the information from eHRSS (including date / time of information being created and accessed, significant findings and conclusion after discussion with the healthcare recipients).
- Healthcare professionals should be aware that they have no obligation to copy all information from eHRSS into their own healthcare recipients' records.
- Healthcare professionals should clearly indicate the source of information, date / time of the information being accessed when copying information from eHRSS in their own healthcare recipients' records.
- In general, reports for third parties (e.g. insurance claims or health check report) should be based on the healthcare professionals' own clinical records and /or assessment of the healthcare recipients. Healthcare professionals should exercise care in case they have to use information from eHRSS for such reference.
- Healthcare professionals should exercise diligence of care in explaining any information accessed through eHRSS to healthcare recipients and not to use them for alleging challenges or criticism in whatever means to disparage or depreciate the professional skills, knowledge, services or qualification of other healthcare professionals and/or healthcare providers. Healthcare professionals are however not prohibited from making fair and honest comments on a colleague if the professional conduct or competence may be called into question.
5. Respect confidentiality of healthcare recipient's information
- Healthcare professionals should respect confidentiality of information obtained from eHRSS.
- Healthcare professionals should be aware that each access to healthcare recipient's eHR will be logged, monitored and audited.
- Healthcare professionals should ensure prior and express consent is obtained from the healthcare recipients before disclosure of any information obtained from eHRSS to any third party.
6. Enquiries and assistance
- Staff designated by healthcare providers as contact points may approach eHR Registration Office for assistance via e-mail firstname.lastname@example.org or telephone 3467 6230.