Il 29/03/2019 20:23, Adrian Klaver ha scritto:
On 3/29/19 9:01 AM, Moreno Andreo wrote:
And I tried to find a solution, and since I did not like that much
what I found (and it seems that neither you do :-) ), I came here
hoping that someone would share his experience to shed some light on
the topic.
From what you have posted the biggest issue you are having is less
then real time search on patient names due to the need to meet
pseudonymisation. To me that is always going to be a problem as there
are two opposing forces at work, overhead to implement
pseudonymisation vs quick lookup. Might be time to lower expectations
on what can be done.
... or just do NOT meet pseudonimization at all, but try to enforce
other rules suggested bu GDPR.
Peter put in evidence a concept
"
The GDPR
doesn't say how to do that at all (the legislators were wise enough that
any attempt to do that would result in a mess). So you can't say "the
GDPR says we have to do it this way" (and if your consultant says that
it is probably time to get a different one). You have to consider all
the risks (and yes, an attacker getting access to some or all of the
data is a risk, but a doctor not being able to access a patient's
records is also a risk) and implement the best you can do considering
"the state of the art, the costs of implementation", etc.
"
that would be absolutely right. I'm not forced to use pseudonimysation
if there's the risk to get things worse in a system. I've got to speak
about these"two opposing forces at work" to a privacy expert (maybe
choosing another one, as Peter suggested :-) ) and ask him if it could
be used as a matter of declining pseudonymisation because of
"pseudonimysation puts at risk overall performance or database integrity"
What do you think?
hp
