Healthcare, GDPR And Data: The Road Ahead

One of the more noteworthy aspects of the 2016 Annual Report of the Data Protection Commissioner (the "DPC"), launched earlier in 2017, was the statement that the Special Investigations Unit of the DPC had finalised preparations to commence an investigation in the hospitals sector this year.¹ The investigation, extending to HSE facilities, private hospitals and voluntary hospitals, is intended to examine the "circulation and journey" of patient files and the processing of patient sensitive personal data in areas of hospitals with patient and public access in order to determine if data protection obligations are being met.

The ramifications of this investigation for hospitals and healthcare facilities could be wide ranging; any negative findings or identified failures would be most unwelcome for the institutions involved as it would damage patient confidence in the security and management of sensitive information held by them in vast quantities.