Hi Gerard,

Gerard Freriks wrote:

/snip/

> In other words: the OpenEHR can assume that the Access Control function
> operates as if it is a fire wall that executes a set of rules
> and that the
> Audit trail is the log with violations (Exceptions) the fire wall had to
> grant.
>
> The operation of the 'firewal' and audit trail are outside the scope of
Open
> EHR.

While I support the concept of seperating the access control functionality
from the storage / retrieval functionality, I'm afraid I have to disagree,
with all due respect, to the segregation of the audit trail and to what I
understand your definition of what needs to be contained in the audit trail.
The notion that the audit trail only log exceptions will be a non-starter
here in the U.S., I think.  The "appropriateness" of an access to a record
can only be determined ex post facto in many cases.  An example may help.
Suppose a nurse prints a copy of one of her patient's records during her
shift.  Is this appropriate access?  On it's face, at the time of access, it
would appear so.  Suppose further,  though, that the nurse later sells that
copy to a third party who uses it to the patient's disadvantage.  Now it's
clear that the access was for inappropriate purposes.  No system can
pre-judge intent.  If the access is not logged, there will be no trail to
the event that led to the inappropriate disclosure and the system will have
contributed to the patient's disadvantage.  Further, unless the list of
accesses is maintained as part of the EHR, there's no guarantee that the
patient will have access to that information.  Thus, I believe the audit
trail functionality must be "in scope" for openEHR, at least to the extent
that the group intends it to be viable here in the U.S..

Best regards,
Bill


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