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Denmark

My Log (DK0057)

Overview

At-a-Glance

Action Plan: Denmark Action Plan 2017-2019

Action Plan Cycle: 2017

Status: Inactive

Institutions

Lead Institution: The Ministry of Health

Support Institution(s): Danish Regions, The Danish Health Data Authority

Policy Areas

E-Government, Health, Public Service Delivery

IRM Review

IRM Report: Denmark Design Report 2017–2019

Starred: No

Early Results: Pending IRM Review

Design i

Verifiable: No

Relevant to OGP Values: Access to Information Technology

Potential Impact:

Implementation i

Completion:

Description

What is the public problem that the commitment will address?: Over the past 10 years, the regional governments have invested in getting digital solutions implemented throughout the healthcare system. Today, workflows at hospitals, general practitioners and healthcare in local governments are to a great extent digitized, and paper-based medical charts have been replaced by electronic health records and digital communication. To strengthen transparency and commination between health professionals, certain health data are available on a joint health record. These data are i.e. data from medical charts from hospi- tals, medication records and lab results. It is compulsory to log all access to health data in Denmark. The log serves as an important tool to ensure lawful access to health data. As workflows are digitized, it is important to ensure citizens’ privacy and that health data is only accessed in accordance with current legislation. Only health care professionals who are giving treatment to a patient are allowed to gain access to information about the particular patient. Due to the joint health records, it is possible for healthcare professionals to share selected information about patients across the health sector, regardless of geog-raphy. All access is logged, and some of these logs are available for citizens in the shared registry solution called Min Log (My Log). This registry allows patients to examine lookups in their joint health record and check whether there has been any incorrect or suspicious lookups. This public logging registration of the health record applies to lookups in the health record via hospitals, the shared medica-tion record, laboratory results, appointments and vaccinations via the webpage sundhed.dk. However, logs from the hospital’s own information systems are not available to citizens yet.; What is the commit-ment?: In the annual budget agreement between the government and the regional governments for 2018 it was agreed that data and information security-work should be of high priority and should be strengthened further to ensure confiden-tiality (and thereby security) of personal sensitive information and a high level of security in the digital infrastructure. This includes ensuring increased transparen-cy of access to the citizens’ health data. On that basis it was agreed that the regional governments in the future adjust-ments of the hospital information systems would be obligated to make sure that is it possible for the citizens to review digital log-information, even when data is processed/accessed through internal systems in hospitals. In addition, it was agreed to analyze how a user-friendly joint public solution could be made acces-sible for citizens via the webpage Sundhed.dk. One of the purposes of Sundhed.dk is to gather all health-related information in one place, where pa-tients can access information about e.g. health record, health related treatments on hospitals, lab results, vaccinations and prescriptions. In addition to access to own health data, sundhed.dk contains information about health services, hospi-tals, health-apps, diseases, etc. Danish Regions is responsible for the analysis, and the analysis itself is ex-pected to be carried out in collaboration with the Danish Health Data Authority. Content, timeline and the organization of the analysis will be completed by the end of 2017.; How will the com-mitment contribute to solve the public problem?: By giving citizens access to log information via Min Log, the individual citizen will be able to see who from the hospitals that have accessed his electronic medical chart and report suspicions of unlawful access of data. This digital registration log helps create transparency and openness about the use of sensitive infor-mation, which is a crucial element in ensuring the balance between increased digitalization and privacy. By implementing the citizen-oriented log-solution, it is the hope that citizens will continue to trust that health data is lawfully accessed.; Why is this com-mitment relevant to OGP values?: The logging registration is relevant to OGP values on transparency and open-ness. The logging-interface ensures that citizens have access to a list with health professionals who have accessed their electronic medical chart as well as what types of information that they have accessed. The purpose is to use transparen-cy to balance privacy and digitisation.; Additional infor-mation: https://www.regeringen.dk/media/3496/aftale-om-regionernes-oekonomi-for-2018.pdf https://www.sundhed.dk/borger/min-side/min-log/min-log/ https://www.sundhed.dk/borger/service/om-sundheddk/om-portalen/datasikkerhed/andres-dataadgang/egenkontrol-min-log/

IRM Midterm Status Summary

Commitment 8: My Log

Language of the commitment as it appears in the action plan:

In the annual budget agreement between the government and the regional governments for 2018 it was agreed that data and information security-work should be of high priority and should be strengthened further to ensure confidentiality (and thereby security) of personal sensitive information and a high level of security in the digital infrastructure. This includes ensuring increased transparency of access to the citizens' health data.

On that basis it was agreed that the regional governments in the future adjustments of the hospital information systems would be obligated to make sure that it is possible for the citizens to review digital log-information, even when data is processed/accessed through internal systems in hospitals. In addition, it was agreed to analyse how a user-friendly joint public solution could be made accessible for citizens via the webpage Sundhed.dk. One of the purposes of Sundhed.dk is to gather all health-related information in one place, where patients can access information about e.g. health record, health related treatments on hospitals, lab results, vaccinations and prescriptions. In addition to access to own health data, sundhed.dk contains information about health services, hospitals, health-apps, diseases, etc.

Danish Regions is responsible for the analysis, and the analysis itself is expected to be carried out in collaboration with the Danish Health Data Authority. Content, time and the organisation of the analysis will be completed by the end of 2017.

Milestones:

8.1 Presentation and clarification of analysis

8.2 Execution of analysis

Start Date: September 2017

End Date: November 2018

Editorial note: For the full text of this commitment, see "The Danish OGP National Action Plan 2017–2019," Danish Agency for Digitisation, https://en.digst.dk/policy-and-strategy/open-government/open-government-partnership-ogp-action-plan/, pp. 19–21.

Context and objectives

Regional governments in Denmark have invested in digital solutions for health care systems over the past decade. By law, all access to health data must be logged, and some of these logs are visible for citizens in a shared registry solution called Min Log (My Log). Through My Log, citizens can see which people at hospitals have handled their electronic patient journal. My Log also makes it feasible to report illegal data use.

Public debate around the balance between digitisation and access to sensitive information continues.[Note : Jakob Sorgenfri Kjær, "Danmark Får en Hær af It-Eksperter, der Skal Beskytte dit Privatliv," Politiken, 13 June 2017, https://politiken.dk/indland/art5992124/Danmark-f%C3%A5r-en-h%C3%A6r-af-it-eksperter-der-skal-beskytte-dit-privatliv. ] The 2018 annual budget between the national government and regional governments emphasised data and information security work as priorities to ensure the confidentiality of personal information. The budget also called for the government to analyse how to make a user-friendly joint public solution available to citizens through the public health page sundhed.dk. (Sundhed.dk gathers all health-related information on one page.) The process began in May 2016, and it is expected to be implemented across all regions by 2020.[Note : Kristoffer Kjærgaard Christensen and Nanna Skovgaard (Ministry of Health), interview by IRM researcher, 29 October 2018.]

This commitment's solution would allow citizens to know which health care professionals have accessed their electronic charts. Thus, it would provide transparency and give citizens increased access to their files, promoting trust in the overall health system.

This initiative is intended to promote transparency and open government. The relevance of this commitment to the OGP values is mainly related to access to information, given its goal of allowing citizens to access their own health data. As a data initiative, the commitment also relates to the technology and innovation for transparency and accountability value. While the commitment seeks to bolster citizen access to information, it does not describe a mechanism to hold authorities accountable through My Log. Therefore, it does not directly support public accountability. However, it does indirectly promote public accountability, as it provides a way for citizens to monitor authorities' use of their health information.

This commitment is, as written, not specific enough to enable verification of its implementation. The text refers to a "study," and the milestones refer to "analysis"— neither of which are clearly defined. The IRM researcher considers the potential impact of this commitment, as described by the milestones, to be minor because it deals with analysis that is not sufficiently explained. Introduction of a log system for citizens to track access to their health files could potentially be transformative. However, it would have to be presented in a clearer way in the next action plan to be considered as such.

The IRM researcher recommends that a future iteration of this commitment refer to implementation of the initiative across the Danish regions, measured by whether they can display log information.

Next steps

The IRM researcher proposes the following recommendations for this commitment:

· Carry the commitment forward to the next action plan, since it has not been implemented fully and reflects the social priority of access to health information at the regional level.

· Reformulate the commitment description and milestones in the next action plan to ensure verifiability, further specifying the various elements of the analysis.

· Building on extensive engagement across Danish regions, share lessons learned at the next multi-stakeholder forum to allow future action plan commitments to be locally anchored.


Commitments

  1. Open Data for Citizens and Media

    DK0050, 2017, E-Government

  2. Data Registers on a Shared Public Distribution Platform

    DK0051, 2017, E-Government

  3. Information Portal for Day-Care Facilities

    DK0052, 2017, E-Government

  4. Open Data and Smart City Forum

    DK0053, 2017, Capacity Building

  5. Open Data DK

    DK0054, 2017, Capacity Building

  6. Overview of Own Cases and Benefits

    DK0055, 2017, E-Government

  7. Nationwide Deployment of Telemedicine

    DK0056, 2017, E-Government

  8. My Log

    DK0057, 2017, E-Government

  9. Civil Society National Strategy

    DK0058, 2017, Marginalized Communities

  10. Report a Rule

    DK0059, 2017, E-Government

  11. OGP Forum

    DK0060, 2017, OGP

  12. Denmark’S Country Program for Uganda

    DK0061, 2017, Aid

  13. The 18Th International Anti-Corruption Conference

    DK0062, 2017, Anti-Corruption Institutions

  14. IATI (International Aid Transparency Initiative)

    DK0063, 2017, Aid

  15. Service Check of Local Government Consultations

    DK0034, 2014, Public Participation

  16. Call on All Municipalities to Facilitate Advance Voting

    DK0035, 2014, Marginalized Communities

  17. Letter of Invitation to First-Time Voters Urging Them to Vote

    DK0036, 2014, Marginalized Communities

  18. User Friendliness Requirements Regarding Digital Self-Service Solutions

    DK0037, 2014, Capacity Building

  19. Plan for Inclusion During the Transition to Digital Communication

    DK0038, 2014, Capacity Building

  20. Common Public Sector Digital Communication Campaign

    DK0039, 2014, Capacity Building

  21. Principles for Collaboration on the Modernisation of the Public Sector as Well as the Establishment of a Centre for Public Innovation

    DK0040, 2014, Capacity Building

  22. “Free Municipality” Pilot Projects

    DK0041, 2014, Subnational

  23. Recommendations from Growth Teams

    DK0042, 2014, Private Sector

  24. Strategy for Digital Welfare

    DK0043, 2014, E-Government

  25. Implementation of a New Charter for Interaction Between Volunteer Denmark/Associations Denmark and the Public Sector

    DK0044, 2014, Civic Space

  26. “Open Data Innovation Strategy” (ODIS)

    DK0045, 2014, Capacity Building

  27. Data Distributor for the Distribution of Basic Data

    DK0046, 2014, Open Data

  28. Open Government Camp 2014

    DK0047, 2014, Capacity Building

  29. Open Government Assistance to Myanmar

    DK0048, 2014, Aid

  30. Opening Key Public Datasets

    DK0049, 2014, Capacity Building

  31. Online Open Government Partnership Community

    DK0001, 2012, E-Government

  32. Online OGP Handbook for Public Authorities and Institutions

    DK0002, 2012, E-Government

  33. Starred commitment Management Labs and New Forms of Co-Operation

    DK0003, 2012, Public Participation

  34. Consultation and Transparency of Development Aid Programmes: Design Aid Programmes

    DK0004, 2012, Aid

  35. Innovate with Aarhus

    DK0005, 2012, Capacity Building

  36. Citizen Self-Services: Increasing the Use of User Ratings in the Citizen’s Port Borger.Dk

    DK0006, 2012, E-Government

  37. Open Government Camp

    DK0007, 2012, OGP

  38. Renewed Effort for Open Government Data

    DK0008, 2012, E-Government

  39. Regional Initiative on Open Data

    DK0009, 2012, Open Data

  40. Reuse of Open Source Software in the Public Sector

    DK0010, 2012, E-Government

  41. Citizen Self-Services: Binding Guidelines for Self-Service Solutions

    DK0011, 2012, Capacity Building

  42. Citizen Self-Services: Guidance and Information on Accessibility to Digital Solutions

    DK0012, 2012, E-Government

  43. Citizen Self-Services: Peer-To-Peer Learning Programmes to Help Citizens Use Digital Self-Service

    DK0013, 2012, Capacity Building

  44. Citizen Self-Services: Location-Based Content and Re-Use of Content in Borger.Dk

    DK0014, 2012, E-Government

  45. Less Reporting Through Increased Re-Use of Key Data

    DK0015, 2012, E-Government

  46. Mypage” for Businesses

    DK0016, 2012, E-Government

  47. Companies to Be “Born Digitally”

    DK0017, 2012, E-Government

  48. Creating a Mediation and Complaints Institution for Responsible Business Behaviour

    DK0018, 2012, Human Rights

  49. International Human Rights Conference

    DK0019, 2012, Human Rights

  50. Promote Social Responsibility in the Fashion Business

    DK0020, 2012, Private Sector

  51. Reporting on Human Rights and the Climate

    DK0021, 2012, Human Rights

  52. Country by Country Reporting in the Extractive and Forestry Industries

    DK0022, 2012, Extractive Industries

  53. Legislative Principles for the Digital Age

    DK0023, 2012, Legislature

  54. Consolidated Key Data

    DK0024, 2012, E-Government

  55. App Store for Digital Learning Resources

    DK0025, 2012, E-Government

  56. Starred commitment Preparing a Digital Reform of the Public Welfare Areas

    DK0026, 2012, E-Government

  57. Consultation and Transparency of Development Aid Programmes: Transparency in Aid

    DK0027, 2012, Aid

  58. Tracking Progress of Universities’ Transition to Digital-Only Administrative Communication

    DK0028, 2012, Education

  59. Disclosure of Status Reporting From the National IT Project Council

    DK0029, 2012, E-Government

  60. Overview of Public ICT Architecture

    DK0030, 2012, E-Government

  61. Publication of Educational Materials on the Government’s ICT Project Model

    DK0031, 2012, Capacity Building

  62. Smart Aarhus and Smart Region: Smart Aarhus

    DK0032, 2012, E-Government

  63. Smart Aarhus and Smart Region: Smart Region

    DK0033, 2012, E-Government