knowledge | 29 June 2017 |

Individual Health Identifiers Update

Key sections of the Health Identifiers Act 2014 (the “Act”) were brought into force on 30 May 2017. The Act provides for the creation of an individual health identifier (“IHI”), which will uniquely identify each person using health or social care services in Ireland and the establishment of the National Register of IHIs (the “Register”) which will contain each individual’s IHI and such other identifying particulars as are known. 

The recent commencement order allows for the operational use of IHIs throughout the Irish healthcare system in line with the terms of the Act.  The introduction of IHIs is intended to improve patient safety by ensuring that the right person is identified and the correct information is associated with every person at the point of care, therefore reducing errors.  IHIs are also intended to increase audibility and traceability for healthcare information by providing a record of who accessed information and when.  No medical information is contained within the Register and people do not need to know their IHI to access services.  It is envisaged that IHIs will also benefit healthcare professionals by enabling them to provide services more securely and effectively.

The sections of the Act which were commenced recently deal with accessing the Register and processing IHIs for the purposes permitted under the Act. These include the provision of a health service to an individual, the promotion of patient safety, including clinical auditing and the investigation and reporting of patient safety incidents, and the identification or prevention of a threat to public health.

Specified persons under the Act may access the Register for a relevant purpose. The definition of specified person is relatively wide and includes health service providers, the Chief Inspector of Social Services, the Child and Family Agency, the Health Research Board, the Irish Blood Transfusion Service, the Irish Medicines Board, the Mental Health Commission, the National Cancer Registry Board, the State Claims Agency, and any other person prescribed by the Minister for Health after consultation with the Data Protection Commissioner.

Specified persons may now also provide an individual’s IHI and such other identifying particulars contained in the Register to the authorised disclosees prescribed in the Act in order to enable them to process the information for a secondary purpose detailed in the Act. A specified person may also, for a relevant purpose, process or further process the above information which the specified person obtained pursuant to, and in accordance with, a provision of the Act.

Our previous briefing on the Health Identifiers Act and implementation of IHIs can be found here.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.

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