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This proposal highlights the importance of protecting personal health information and the use of mechanisms such as data encryption, pseudonymization/anonymization, and access control. It suggests extending the PIX Integration Profile to implement the IPT Profile and addresses the need for pseudonymization in primary use scenarios.
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Identification Protection Token (revised) Brief Profile Proposal for 2008/09 presented to the IT Infrastructure Planning Committee A. Kassner (IHE-D), J. Caumanns (eCR) 08 October 2008
Identity Protection • From the perspective of European privacy regulations, all data that is suited to create a link between a person and information about this person’s state of health has got a high or even very high demand for protection. With respect to confidentiality this means that mechanisms such as data encryption, pseudonymization/anonymization, or rigid access control have to be applied.
IPT and PIX • For data that is target to server-side querying or filtering, encryption cannot be used. For this all registry and access control data [accessible through the internet] that is organized with respect to a certain patient, must not be linked to any data that is suitable to identify the patient as an individual. Instead it must be organized using key data that protects the identity of the patient. • »The PIX Integration Profile achieves the integration of disparate Patient Identifier Domains by using a cross-referencing approach between Patient Identifiers associated with the same patient.« [ITI TF-1 v4.0#5.4]
Discussion • PIX can be extended to implement the IPT Profile, but it was not designed for that • Pseudonymization and Anonymization are services of a security subsystem and should be handled as such (e. g. compatibility with XUA) • The proposed XCPI profile addresses use cases where pseudonymization is required • => There is a need for pseudonymization in primary use scenarios. These should be analysed in the white paper proposed as ITI#14. A dedicated profile would then be a second step.