eHRSS Made Easy

With the Electronic Health Record Sharing System (eHRSS) just coming on stream, the Electronic Health Record Office (eHR Office) has prepared a set of frequently asked questions (FAQs) to address common concerns over the new system from healthcare providers (HCP) and healthcare recipients (HCR) respectively.

The FAQ covers registration, legal aspect, data privacy and system security of the eHRSS.

eHRSS Registration

I have my own clinic and I am also a visiting medical officer (VMO) of some private hospitals, what should I do in order I can view patients’ eHR in both places?

eHRSS registration is HCP-based. Only HCProfs working in the HCP could view the eHR on a need to know basis. If you are the owner of a clinic, it is advisable that the clinic (e.g. Dr Chan Tai Man Clinic) should be registered as a HCP. If you wish to access eHR in another HCP (e.g. a private hospital), you will need respective HCP to allow you to use its computer systems (e.g. open a user account for you).

We are a group practice with clinics all over Hong Kong. Is it possible that only some of the clinics join the eHRSS?

HCP can apply to the eHR Commissioner to register all or some of the healthcare institutions / clinics providing care under its supervision to participate in eHR sharing.

Is it essential for HCPs to provide eHR patient registration service?

The eHR Office anticipates that some HCPs, especially those in solo practice or small group practice would not be able to provide eHRSS patient registration service. HCPs can inform patients to register for eHRSS via online, postal mail, fax, drop-in box at eHR Registration Office or in person at their nearby eHR Registration Centres. The list of eligible HCPs and eHR Registration Centres have been made publicly available.

My clinic has participated in the Public Private Interface – Electronic Patient Record Sharing Pilot Project (PPI-ePR) and Public-Private Partnership (PPP) programmes, but we do not want to join the eHRSS at the moment. Can I still access the PPI-ePR and look after my existing PPI and PPP patients when the eHRSS is launched?

PPI-ePR will continue to run for a period of time after eHRSS is launched. During the transitional period and if you have not joined eHRSS:

a)   You can still access the health record of existing PPI-ePR and PPP patients. b)   You will not be able to access health records of new patients who have joined the eHRSS after the eHRSS launch.

What if I have joined the eHRSS but my existing PPI-ePR / PPP patients have not joined the eHRSS after the eHRSS launch?

a)   PPI-ePR will continue to run for a period of time after the eHRSS is launched. b)   During the transitional period, you can still access the health record of existing PPI-ePR and PPP patients who have not joined eHRSS. Only data from the HA will be shared. c)   Once your existing PPI-ePR / PPP patients have joined eHRSS and provided sharing consent to your HCP, you will be able to access their health records shared from other HCPs for whom they have given sharing consent.

Legal Concerns

What is my legal liability if I miss some relevant information in the eHRSS when caring for my patients?

eHR participation is voluntary for HCPs and HCProfs. There is no mandatory requirement for a HCProf to join the eHRSS or read all information in a patient’s record in the eHRSS. HCProfs shall exercise professional judgement to interpret the information in the eHRSS and consider what information shall be accessed for reference purpose.

Is it essential to share data and is there any legal liability for not sharing data if I have joined the eHRSS?

There is no obligation for HCPs to share their patients’ records which are not electronically readily available for sharing. It is not an offence under the eHRSS Ordinance (eHRSSO) for not sharing data. However, it is a deviation from the conditions of participation. It is advisable for HCPs to consider implementing or upgrading their electronic medical record (eMR) systems for sharing more data within the sharable scope. There are free eMR packages available for the private sector to enable the sharing of information through the eHRSS. The eHR Office also works with major vendors of clinic software to support data uploading.

Is there any high risk of legal liability after joining the eHRSS as the eHRSSO has introduced offences for misusing eHR?

No. The offences mostly deal with unauthorised access to eHR, causing damage or impairing the system with malicious intent, or using eHR for direct marketing purpose.

eHRSS Registration

How can I participate in the eHRSS?

The eHRSS was launched on 13 March 2016. HCRs can voluntarily register in person at the eHR Registration Centres. Alternatively they can submit the registration form online, by post or fax (3467 6099) to the eHR Registration Office, or via drop-in-box at the eHR Registration Office. Registration form and the address of the eHR Registration Centres are available at the eHRSS website at www.ehealth.gov.hk.

Privacy and Security

How will my eHR be protected?

Protection of patient data privacy and system security is of paramount importance in developing the eHRSS. In addition to the various technical measures to be put in place (e.g. data encryption, firewalls, identity authentication of patients and healthcare professionals) and the legal protection currently provided under the Personal Data (Privacy) Ordinance (Cap.486), we have also formulated the eHRSS Ordinance (Cap. 625) to help safeguard the privacy and security of the eHRSS and its data. Besides, Privacy Impact Assessment and Security Risk Assessments and Audits have been conducted prior to the launching of the eHRSS, and a Privacy Compliance Audit is planned to be conducted some time after launching.

What does it mean by joining eHRSS?

Joining eHRSS You agree to let eHRSS store your personal identification and health data from participating healthcare providers (HCPs) who have obtained your consent. You agree Hospital Authority (HA) and Department of Health (DH) to view and upload your health record. Providing Sharing Consent You agree to let a particular HCP view and upload your health record.

Can all participating Healthcare Providers (HCPs) view my eHR after I joined?

Sharing Consent Participating HCPs will not automatically have the right to read the eHR of all registered healthcare recipients (HCRs). HCPs need to obtain HCR’s consent before viewing HCR’s medical records. Notification All access will be logged. HCRs can choose to receive notification through the means they preferred whenever their eHR are accessed.

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