1. Background – What is the Electronic Health System?
  2. Part I – How can an HCR give Joining or Sharing Consent in eHealth?
  3. Part II – What to know about eHealth?
  4. Part III – What are the matters relating to registration and de-registration?
  5. Part IV – Any other matters an HCR or SDM acting on behalf of an HCR should be aware of?
  6. Part V – Matters relating to provision and obtainment of sharable data by HCRs and Related Persons
  7. Glossary

 

Background – What is Electronic Health Record?

The Electronic Health System (eHealth) is an information infrastructure established pursuant to section 5 of the Electronic Health System Ordinance (Cap. 625) (eHealth Ordinance) for keeping and sharing electronic health records (eHRs) and for providing support in connection with, or facilitating, the provision of healthcare or health management. eHRs contain a person’s personal and health-related information. With the person’s express and informed consent, healthcare providers (HCPs) in the public and private sectors may access the person’s eHRs for healthcare purposes through eHealth.

Any person, for whom healthcare has been performed, is performed or is likely to be performed (i.e. a healthcare recipient (HCR)) can apply to join eHealth. If the HCR is a minor (under 16 years old) or lacks the required mental capacity to join eHealth, a person known as a “substitute decision maker” (SDM) can assist the HCR to join eHealth.

 

Part I – How can an HCR give Joining or Sharing Consent in eHealth?

For Consent given before 1 December 2025

Joining Consent

  1. An HCR or SDM on behalf of an HCR must give a joining consent when applying to join eHealth.
  2. By giving joining consent, the HCR or his/her SDM agrees to let the Commissioner for the Electronic Health Record (eHRC) share the HCR's sharable data in eHealth, for healthcare and referral purpose, with any prescribed HCP who has been given sharing consent by the HCR or his/her SDM. When the joining consent is given, the HCR or SDM on behalf of the HCR is taken to have given sharing consent to the Department of Health (DH) and the Hospital Authority (HA).
  3. However, if an HCR gives a joining consent on or after 1 December 2025, the joining consent is to be treated as a joining consent given on or after 1 December 2025.

 

Sharing Consent

  1. eHealth will not automatically allow prescribed HCPs (other than DH and HA) to access an HCR’s health data kept in eHealth. The HCR or his/her SDM may choose to separately give a sharing consent to a prescribed HCP participating in eHealth who is providing or is about to provide healthcare to the HCR.
  2. Prescribed HCPs who have been given sharing consent can provide to and obtain from eHealth the HCR’s sharable data, and can share it with another prescribed HCP for healthcare referral purpose.
  3. The HCR or his/her SDM can choose to give sharing consent to a prescribed HCP for an indefinite term or for a one-year renewable period (other than DH and HA for whom the sharing consent is taken to be valid as long as the HCR is participating in eHealth).
  4. The HCR or his/her SDM can revoke any sharing consent given to a prescribed HCP (other than the sharing consent for DH and HA) at any time.
  5. All sharing consents will be terminated if the HCR or his/her SDM on behalf of the HCR withdraws from eHealth or if the HCR's registration is cancelled by the eHRC.
  6. For a sharing consent given before 1 December 2025, the relevant provisions in the eHealth Ordinance shall continue to apply in relation to the consent on or after 1 December 2025 as if the former relevant provisions had not been amended, i.e. in indefinite term or a one-year renewable period (other than DH and HA for whom the sharing consent is taken to be valid as long as the HCR is participating in eHealth).

 

For Consent given after 1 December 2025

Joining Consent

  1. An HCR or SDM on behalf of an HCR must give a joining consent when applying to join eHealth.
  2. By giving a joining consent, the HCR or his/her SDM agrees to let the eHRC (i) obtain the HCR’s sharable data from any relevant HCP or recognized non-Hong Kong public health record system, (ii) obtain from a specified HCP any specified health data of the HCR, (iii) share the HCR’s sharable data in eHealth with any relevant HCP or recognized non-Hong Kong public health record system who has been given sharing consent by the HCR or his/her SDM, and (iv) (if a prescribed HCP has made a healthcare referral to another prescribed HCP) provide to that other prescribed HCP the HCR’s sharable data relevant to the healthcare referral.
  3. The joining consent also allows a relevant HCP to provide the HCR’s sharable data to eHealth, and allows any sharable data of the HCR to be provided to eHealth from a recognized non-Hong Kong public health record system.
  4. When the joining consent is given, the HCR or his/her SDM on behalf of the HCR is taken to have given sharing consent to the DH, HA, the Primary Healthcare Commission (PHCC), and healthcare facilities managed or controlled by the Government, the HA, or an HA subsidiary (Government and HA Facilities).
  5. For the full list of Government and HA Facilities, please visit www.eHealth.gov.hk.

 

Sharing Consent

  1. eHealth will not automatically allow relevant HCPs or a recognized non-Hong Kong public health record system (other than DH, HA, PHCC, and Government and HA Facilities) to access an HCR’s health data kept in eHealth. The HCR or his/her SDM may choose to separately give a sharing consent to them, who is providing or is about to provide healthcare to the HCR.
  2. An HCR or his/her SDM can choose to give sharing consent to any of the relevant HCPs or in relation to any of the recognized non-Hong Kong public health record systems, other than DH, HA, PHCC, and Government and HA Facilities for whom the sharing consent is taken to be valid as long as the HCR is participating in eHealth.
  3. The sharing consent being given to any of the relevant HCPs or in relation to any of the recognized non-Hong Kong public health record systems after 1 December 2025 will be in effect until the HCR’s registration is withdrawn from eHealth or cancelled by the eHRC or the sharing consent is revoked.
  4. The HCR or his/her SDM can revoke any sharing consent given to a relevant HCP or in relation to any of the recognized non-Hong Kong public health record systems (other than the sharing consent for DH, HA, PHCC, and Government and HA Facilities) at any time.

 

Ways of Giving Consent

HCR may:

  1. use his/her Hong Kong Identity Card (Smart ID) as a means to give joining consent and/or sharing consent, by inserting his/her Smart ID into a Government-approved card reader, allowing the retrieval of card face data (including the HCR’s name, date of birth, sex and identity card number); or
  2. choose to give joining and/or sharing consent by signing on a printed form; or
  3. choose to give sharing consent by using his/her Access Key (a unique number assigned to him/her upon his/her registration to eHealth); or
  4. use "iAM Smart" to give joining consent during online registration with eHealth; or
  5. choose to give joining consent and/or sharing consent via the eHealth App.

 

Part II – What to know about eHealth?

Protection of eHRs

  1. eHRs in eHealth is under the protection of the eHealth Ordinance and other relevant laws in Hong Kong, including the Personal Data (Privacy) Ordinance (Cap. 486) (PD(P)O).
  2. Under emergency situations when an HCR is incapable of giving sharing consent to a prescribed HCP (e.g. the HCR has been injured in an accident), his/her eHRs may be accessed by HCPs for or in connection with the carrying out of emergency rescue operations or the provision of emergency relief services.
  3. All access and use of eHRs in eHealth must be under proper authorisation and will be logged and subject to audit.
  4. An HCR or his/her SDM will receive notifications through the communication means chosen by him/her when his/her eHRs in eHealth have been accessed.

 

Sharable Data in eHealth

Scope of sharable data is defined based on professional advice. Only data within sharable scope will be shared on eHealth. The scope of sharable data will be reviewed and updated from time to time. The joining and sharing consent given will remain valid for any changes in sharable scope. The scope of sharable data include the following:

  1. Personal Identification and Demographic Data (including name, date of birth and identity document number, etc.);
  2. Allergies and Adverse Drug Reactions;
  3. Diagnosis, Procedures and Medication;
  4. Encounters / Appointments (e.g. summary of appointments / bookings);
  5. Clinical Note / Summary (e.g. Discharge Summary);
  6. Birth and Immunisation Records;
  7. Laboratory and Radiology Reports;
  8. Other investigation reports;
  9. Healthcare Referrals;
  10. Observation (e.g. blood pressure and blood sugar records) and Lifestyle (e.g. smoking and drinking habit) Records; and
  11. Medical Certificate.

The latest scope and details will be published on the eHealth website (https://www.ehealth.gov.hk/).

 

Use of eHRs

Data in eHealth may be used for improvement of healthcare, in connection with advance medical directives, disease control and surveillance, emergency situations, Government-authorized healthcare programmes, formulation of public policies, or as permitted under any other law. Data in eHealth may also be used for research and statistics after the relevant provisions in the eHealth Ordinance come into operation.

 

Benefits and Limitations of eHealth

eHealth contains an integrated summary of an HCR’s health information contributed by different HCPs. It is not a complete record of an HCR’s entire health history and it shall not be taken as a replacement of patient records kept by HCPs. HCR should inform his/her HCPs all relevant health information when receiving healthcare service.

 

Part III – What are the matters relating to registration and de-registration?

Registration

An HCR may join eHealth by giving joining consent and allow sharing of his/her eHRs by giving sharing consent if he/she is able to understand the purpose and implications of joining eHealth.

 

Important Notes for SDM Handling Registration Matters on Behalf of a HCR

For an HCR under 16, or aged 16 or above and fulfills any of the following descriptions, a SDM may act on behalf of an HCR for eHealth registration matters, including giving of joining consent and sharing consent or revocation of a sharing consent, and request for withdrawal of participation in eHealth:

  1. Mentally incapacitated as defined by section 2(1) of the Mental Health Ordinance (Cap. 136); or
  2. Incapable of managing his or her own affairs; or
  3. Incapable of giving joining consent at the relevant time as defined in the eHealth Ordinance; or
  4. Incapable of giving sharing consent at the relevant time as defined in the eHealth Ordinance.

A SDM shall confirm that the person whom he/she is acting for and on behalf of meets the conditions for requiring an SDM as listed above.

A SDM may handle eHealth registration matters for and on behalf of an HCR by submitting an application form in person at the Electronic Health Record Registration office (eHR RO) or at one of the eHR Registration Centres or sending an application form to eHR RO by way of fax, postal mail or drop-in box.

When making the application on behalf of the HCR (e.g. when the consent is given by signing on the application form and sent to the eHR RO), the SDM should be accompanying the HCR and have regard to the best interests of the HCR.

The SDM shall be responsible for all matters regarding eHealth registration while acting for and on behalf of the HCR in the circumstances.

The SDM shall ensure that he/she is an eligible SDM in accordance with the following requirements.

 

Eligible SDM for HCR under 16
  1. the person's parent;
  2. the person's guardian1;
  3. a person appointed by court to manage the person's affairs;
  4. if there is no one in (a)-(c), the person's family member or a person residing with him/her;
  5. if there is no one in (a)-(d), the prescribed HCP who provides or is about to provide healthcare to him/her.

 

Eligible SDM for HCR aged 16 or above and is incapable of giving the person's own consent
  1. the person's guardian2;
  2. the Director of Social Welfare or any other person as guardian under the Mental Health Ordinance (Cap. 136) (MHO)3 ;
  3. a person appointed by court to manage the person's affairs;
  4. if there is no one in (a)-(c), the person's family member; or a person residing with him/her;
  5. if there is no one in (a)-(d), the prescribed HCP who provides or is about to provide healthcare to him/her.

 

Withdrawal of Registration

  1. An HCR or SDM on behalf of an HCR may at any time request for withdrawal of the HCR’s registration.
  2. The eHRC will notify the HCR or his/her SDM when the withdrawal takes effect.
  3. Once withdrawal is effective, the HCR’s sharable data cannot be obtained from or provided to eHealth by any relevant HCP or any recognized non-Hong Kong public health record system.

 

Suspension of Registration

  1. The eHRC may suspend an HCR’s registration to eHealth if the eHRC reasonably suspects that certain circumstances as listed in the eHealth Ordinance occurred, including the HCR has contravened the eHealth Ordinance or a condition for the registration.
  2. The eHRC will notify the HCR or his/her SDM when the suspension or lifting of the suspension takes effect and the reasons for the suspension.
  3. Once suspension is effective, the HCR’s new data or information may still be provided to eHealth but his/her eHRs will not be made available to any relevant HCP or be provided to any recognized non-Hong Kong public health record system.

 

Cancellation of HCR’s Registration

  1. The eHRC may cancel an HCR’s registration if the eHRC is satisfied that certain circumstances as listed in the eHealth Ordinance occurred, including the HCR has contravened the eHealth Ordinance or a condition for the registration, or the HCR has died.
  2. The eHRC will notify the HCR or his/her SDM when the cancellation is effective and the reasons for the cancellation. If the HCR has died, cancellation takes effect on the day the eHRC has confirmed the death information.
  3. Once cancellation is effective, the HCR’s new data or information cannot be provided to eHealth by any relevant HCP, specified HCP or any recognized non-Hong Kong public health record system. The eHRs of the HCR will not be made available to any relevant HCP or be provided to any recognized non-Hong Kong public health record system through eHealth.

 

Revocation of Sharing Consent

  1. An HCR or an SDM on behalf of an HCR may at any time revoke a sharing consent given to any relevant HCP or in relation to any recognized non-Hong Kong public health record system (but not DH, HA, PHCC, and Government and HA Facilities).
  2. The eHRC will notify the HCR or his/her SDM when the revocation takes effect.
  3. Once revocation is effective, the HCR’s sharable data cannot be obtained from eHealth by the relevant HCP or the recognized non-Hong Kong public health record system.

 

Protection of Personal Data Privacy

  1. A series of policies, guidelines and best practices for the collection, retention, uses, disclosure, protection and facilitation of access and correction of personal data contained in eHealth has been adopted to ensure compliance with the relevant laws.
  2. Reasonably practicable steps shall be taken to protect the personal data against any unauthorised or accidental access, processing, erasure, loss or use.
  3. Different retention periods are applied to the various kinds of personal data kept in eHealth in accordance with the respective Data Retention Policy. The personal data shall not be kept longer than necessary for the fulfilment of the purposes for which the data is or is to be used.

 

Part IV – Any other matters an HCR or SDM acting on behalf of an HCR should be aware of?

How to Obtain a Copy of or Amend the Record in eHealth

An HCR or SDM on behalf of an HCR may obtain a copy of the HCR’s personal information kept in eHealth and submit correction requests for such information according to PD(P)O.

 

How to Appeal against Decisions regarding the Registration

If a person disagrees with the eHRC’s decision in refusing to register him/her or to suspend or cancel the person’s registration, the person may within 28 days from the date of receipt of the relevant notice in writing, appeal to the Administrative Appeals Board.

 

Limitation of the eHRC’s Responsibility

Please take note that:

  • The eHRC makes no representation or warranty regarding eHealth on –
    • its fitness for a particular purpose;
    • its freedom from computer virus or other use as a conduit to damage others’ systems; and
    • its availability and proper functioning at any time.
  • The eHRC is not responsible for the delivery of data over the Internet or handling of data by systems that are not owned or operated by the eHRC.
  • The eHRC is not liable for –
    • any unauthorised access or use of eHRs but the eHRC will take appropriate and reasonable steps to protect the security of the data in eHealth;
    • any direct, indirect, special or consequential losses or damages arising from access to or use of eHealth, use of any eHRs in eHealth, or providing or obtaining data or information to and from eHealth; and
    • any liability that is excluded by eHealth Ordinance.
  • The eHRC does not guarantee the accuracy, completeness or correctness of the data kept in eHealth as the data are contributed by the HCRs or their SDMs, and by the relevant HCPs, specified HCPs or recognized non-Hong Kong public health record systems.

 

Part V – Matters relating to provision and obtainment of sharable data by HCRs and Related Persons

An HCR, or a related Person of the HCR, may provide to or obtain from the eHealth any sharable data of the HCR in the form and manner specified by the eHRC.

Related Persons

In relation to a HCR, related persons means -

  1. a relevant person of the HCR, which has the meaning given by section 2(1) of the PD(P)O; and the reference to a minor shall be a reference to a person below 16 years of age; or
  2. a person who is authorized by the HCR in the form and manner specified by eHRC.

 

Validity of authorization

The authorization is in effect until -

  1. the registration of the HCR is withdrawn from the eHealth;
  2. the registration of the HCR is cancelled; or
  3. the authorization is revoked by the HCR in the form and manner specified by eHRC.

 

Further enquiries

An HCR or SDM may contact the following for more information:

Electronic Health Record Registration Office
Address: Unit 1102, 11/F, Harbourside HQ, 8 Lam Chak Street, Kowloon Bay, Hong Kong.
Hotline: (852) 3467 6300
Fax: (852) 3467 6099
Email: ehr@ehealth.gov.hk
Website: https://www.ehealth.gov.hk/

 

Glossary

  • DH means the Department of Health.
  • Electronic Health Record (eHR) means health-related data and information, including the Healthcare Recipient Index Data, of HCRs stored on the eHealth.
  • Effective date means 1 December 2025, the effective date of the Electronic Health Record Sharing System (Amendment) Ordinance 2025.
  • eHRO means the Electronic Health Record Office.
  • eHR RO means the Electronic Health Record Registration Office.
  • Electronic Health System (eHealth) means an information infrastructure established pursuant to section 5 of the Electronic Health System Ordinance (Cap. 625) for keeping and sharing electronic health records and for providing support in connection with, or facilitating, the provision of healthcare or health management.
  • Electronic Health System Ordinance (Cap. 625) (eHealth Ordinance) means the Ordinance which provides for the establishment of eHealth, the sharing and using of data and information stored in eHealth, the protection of eHealth, data and information; and to provide for incidental and related matters, which is amended by the Electronic Health Record Sharing System (Amendment) Ordinance 2025 with effect from 1 December 2025.
  • Government and HA facilities means healthcare facilities managed or controlled by the Government, the HA, or an HA subsidiary.
  • HA means the Hospital Authority.
  • Healthcare provider (HCP) means a person that provides healthcare in Hong Kong or elsewhere.
  • Healthcare recipient (HCR) means an individual for whom healthcare has been performed, is performed, or is likely to be performed in Hong Kong or elsewhere.
  • PD(P)O means the Personal Data (Privacy) Ordinance (Cap. 486).
  • PHCC means the Primary Healthcare Commission.
  • Prescribed HCP means (i) DH, (ii) HA, (iii) PHCC, (iv) Government and HA Facilities, or (v) a registered HCP.
  • Related person, in relation to an HCR, means a relevant person of the HCR or a person who is authorized by the HCR to (i) provide to eHealth, or (ii) obtain from eHealth any sharable data of the HCR in the form and manner specified by the Commissioner.
  • Relevant HCP means a Prescribed HCP or a recognized non-Hong Kong HCP.
  • Relevant person has the meaning given by section 2(1) of the PD(P)O. In relation to an HCR means -
    1. where the HCR is a minor, a person who has parental responsibility for the minor;
    2. where the HCR is incapable of managing his own affairs, a person who has been appointed by a court to manage those affairs;
    3. where the HCR is mentally incapacitated within the meaning of section 2 of the Mental Health Ordinance (Cap. 136)
      1. a person appointed under section 44A, 59O or 59Q of that Ordinance to be the guardian of that individual; or
      2. if the guardianship of that individual is vested in, or the functions of the appointed guardian are to be performed by, the Director of Social Welfare or any other person under section 44B(2A) or (2B) or 59T(1) or (2) of that Ordinance, the Director of Social Welfare or that other person.
  • Sharing means the act of providing or obtaining any sharable data of a HCR through eHealth.
  • Specified HCP means an HCP who is required to provide specified data of an HCR to eHealth in the form and manner specified by the eHRC pursuant to section 26Q of the eHealth Ordinance.
  • Substitute decision maker (SDM) means an eligible person giving consent on behalf of and in the name of the HCR under the requirements of eHealth Ordinance.
  • The Commissioner for the Electronic Health Record (eHRC) means the public officer appointed under section 48 of the eHealth Ordinance to operate and maintain the eHealth.
  • Use, in relation to any data or information contained in an eHR, includes disclosure and transfer of the data or information.

 

1. Appointed under or acting by virtue of the Guardianship of Minors Ordinance (Cap. 13) or appointed by court. 2. Appointed under the Mental Health Ordinance (Cap. 136). 3. Appointed under sections 44A(1)(i), 44B(2A) or 59T(1), or 44B(2B) or 59T(2) of the Mental Health Ordinance (Cap. 136).

 

We keep our Participant Information Notice under regular review.