Medical data protection: A proposal for a deontology code

Journal of Medical Systems, Vol. 14, No. 6. 1990

Medical Data Protection: A Proposal for a Deontology Code* D. G r i t z a l i s , t ' ~ A. T o m a r a s , t J . Keklikoglou,t

S. K a t s i k a s , t ' $ and

In this paper, a proposal for a Medical Data Protection Deontology Code in Greece is presented. Undoubtedly, this code should also be of interest to other countries. The whole effort for the composiffon of this code is based on what holds internationally, particularly in the EC countries, on recent data acquired from Greek sources and on the experience resulting from what is acceptable in Greece. Accordingly, policies and their influence on the protection of health data, as well as main problems related to that protection, have been considered.

INTRODUCTION Any code can be considered as solemnization of experience in the form of a set of rules. A code is adopted by a community because its members accept that obedience to the rules of this code, including constraints resulting by these rules, are to the benefit of the community. It can be said that everything included in an acceptable code is obvious and expresses the common sense but this does not mean diminution of the code's value. The conscientious selection that takes place and the emphasis rendered, with respect to a group of items of common sense based on experience, constitute by themselves a remarkable function. The composition of a Health Informatieians' Deontology Code (HIDEC) in Greece is the main aim of the present paper. However, this HIDEC should also be of interest to other countries. The community, where the HIDEC should apply, consists of the informaticians, working in connection with the users of computers in the health sector. The HIDEC will refer to the practice and behavior, according to which the health informaticians are expected to exercise their profession, offering their services, but also to the

From the ?Technological Educational Institute (TEl) of Athens, Department of Informatics, Ag. Spyridonos Street, Aegaleo 12210, Athens, Greece; ~University of the Aegean, Department of Mathematics, Karlovassi 83200, Samos, Greece. * This work was supported in part by the Greek Ministry of Health, Welfare and Social Services. 375 0148-5598/90/1200-0375506.00/0 © 1990 Plenum Publishing Corporation

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practice and behavior expected from the users. The whole effort for the composition of the HIDEC will be based on: 1. What holds internationally, but particularly on what holds in the EC countries. 2. The data acquired very recently from Greek sources. 3. The experience resulting from what is acceptable in Greece socially and scientifically. POLICIES ON THE PROTECTION

OF HEALTH DATA

Great attention is given to the protection of the professional secret in the health area because health belongs to the social ethics, which are part of our life. 2 Often, this protection does not refer specifically to health, but is covered by measures related to every kind of professional secret. Certainly, the authorities are confronted with the need to allow exemptions to the professional secret. 3 Exchange of health data and information, governed by legal procedures, takes place in almost all countries, 4 without this being considered as violation of the professional secret. On the other hand, various health bearers assure the application of the relevant rules and principles. However, exemptions referring, e.g., to research or statistics on health data and training to the medical profession are in general acceptable. The policies on the protection of health data into different countries are not static. So, the respective legal arrangements are delayed and where they do not exist, the problems are tackled through the penal law, which covers the professional secret and the health data, rendering responsibility to the health personnel. In some countries, like France, it is believed4 that the health data should be governed by special rules, so that the citizen's rights are in harmony with the rights of the society. In general, it is acceptable that the protection of health data should be improved. Some countries are characterized by different beliefs, e.g., Sweden, where the general principle of free access to public files and documents and consequently to every kind of health data, is in power. In some countries, where there is no legislation on data protection, the health data secret is preserved by the medical ethics. In the United Kingdom, 1,6 where law is basically traditional, medical ethics played an important role in introducing special directives on health data protection, in the frame of the existing act for the protection from the automated data collection and processing. In Spain, the need for restriction of information use and therefore of information use of health data is anticipated constitutionally. In Denmark 7'8'9'1° the use of computers in health has been developed for 25 years now. So the sensitivity of the Danes led to legislation with basic principle referring to the medical professional secret. APPLICATION OF POLICIES ON THE PROTECTION HEALTH DATA

OF

Legal Measures We go through a period of intensive legal research in the data protection area with special interest in the protection of health data. 1,4,11 In countries where there is extensive

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legislation already, this refers in general to the secrecy of data processing and to the data statistical processing but not specifically to information relevant to health. In Sweden, 12 there exists the principle that every citizen is entitled to free access to all public files. However, the infliction of some restrictions on this right has been considered necessary in certain cases, which are referred to in the law of January l, 1981. As far as health data are concerned, the term " d a m a g e " of this law refers to the area of Public Health, to the Care of the Mentally Retarded, and to the Social Services. That is, there are various kinds of restrictions in order to prevent the damage to the personality of an individual from possible use of information about his health. The rules of the Swedish Law on Information Protection are obligatory for everyone in the health community. The free exchange of information within a hospital refers only to the necessary information required to secure the medical care of a patient. During the transactions between state authorities, the principles of the Law should be taken into account. Let us look at two interesting cases. If a patient provides information related to another person this will be kept secret. On the other hand, personal information on health is given not necessarily with a patient's consent if it only concerns his required medical treatment. In Denmark, v'8 an act has passed in 1970, aiming at the greater publicity on subjects handled by the public administration. However, the personal health data are exempted from publicity. Only the person concerned can have access to his personal health data. In 1974, a revised law allowed the Social Authorities to request extensive information from anyone who would ask for a service from them, including also hospital file information. This is an official conflict to the professional secret and an exemption from the relevant rules that secure it. In 1978, two acts passed, regarding computer records, specifically, the "Danish Law of Individual Records" and the "Danish Law of Public Authorities Records." Health computer records were in being before these two laws, without any observation of misuse. These two laws, with the mechanisms of supervision and control that provide and with the rules of maintenance and use of computer records that introduce, succeeded in their goal, that is, in the improvement of data protection, including health data. In Finland 4 some efforts were made, in 1970, to solve problems related to data protection, but definite solutions have not been found. In 1980, a committee was established for the data protection. The general principles which have been formulated by this committee are the following: 1. The recording of personal data--including health data--should be made according to the rules of the relevant law. 2. There is an objective necessity for personal data recording, according to the needs of a certain archivist. 3. The need to impose restrictions on the recording of the health data of an individual is recognized. These data refer to the state of health of an individual, to his illnesses, to his disability, and to the medical treatment given to him. 4. The obligation for correction of incorrect data is established. 5. Restrictions are established on the flow of data. 6. The right of an individual to control his personal data and to know the reason of their existence and use is established. In Spain, article 18.4 of the Constitution of 1978, defines that "the law will restrict the use of information, so that the honor and the personality of an individual and of his

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family, as well as the exercise of their rights, is secured." The Penal Code requires from the civil servants to maintain the secrecy on all information which is characterized as confidential. In particular, as far as health data are concerned, the decree 2082/78 on what is in power in the administration and management of hospitals, in article 13, defines the right of the patients to enjoy confidentiality on their personal health data. In France, the professional secret anticipated in article 378 of the Penal Code can only be violated for reasons of "public interest" and this violation is allowed only by law. Such cases are death and birth declaration, certain infectious diseases, certificates of maternity and child protection, social security, etc. Thus, it is anticipated that the circulation of health data occurs for reasons related to public interest. Any computer-based information system in order to function must have the permission of the "National Committee of Information." This Committee cares for the whole information system, for the information included in it, for its security, and for the confidentiality of the use of this information. It cares also for the right of access of an individual to information regarding him. The Committee cares also for the right of "silence and forgetfulness" on personal data of an individual. However, the informaticians are not bound by the professional secret so that they can manage the various information through computers. In Belgium, the legislation aims at the protection of some aspects of the private life, including medical data. The objective goals are: 1. The provision of the necessary data for the control of the expanding technology and 2. The securement of the protection of the private life. In Poland, the basic legislation connected to the health data protection was established in the 50s. The protection of every kind of information related to the health of a citizen is secured by the Law on the Medical Profession, which came in power in October 1950. Article 14, paragraph 1 of this law, defines that "the doctor will keep secret, all information acquired during the exercise of his profession." This principle does not hold in certain cases such as: 1. When there is consent from the patient or the doctor responsible to provide information related to the patient, to third parties. 2. When the doctor is obliged by other laws to provide information (on infectious diseases). Then, information is treated as secret. 3. When secrecy can endanger the patient's life or his environment. 4. When the doctor is obliged to inform an authorized person on medical data of someone (testimony in the court of justice). 5. In case of murder or serious injuries or poisoning or light wounds during the commitment of a crime. Then, the doctor is obliged to inform the proper authorities. In Turkey, Law 53 gives the right to the State Statistical Institute to collect health and other statistical information. The same Law allows the Public Administration bearers to collect statistical data from the institutions related to them, only after permission. Within this legislation, the Ministry of Health and Social Aid can collect statistical data from all Health Institutions in Turkey. In Hungary, 13 the regulation of the activity of the people related to the medical profession exists for hundreds of years now. So, the decree "Generalie Normativum Sanitatis" of 1770 gave a thorough analysis of the strict obligations of the doctors and

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indicated the moral rules which should govem their activities. The " L a w of Health Services" of 1972 activated the obligations occurring from the medical secret. The most important of these obligations are: 1. The doctor must provide information that concerns the state of health of a person if he is asked by the person himself or by his relatives, in case of need. 2. If a person has been characterized as partially or totally unable, then the doctor can inform his relatives on the state of his health, only if this contributes to his cure or to the improvement of his health condition. 3. The pharmacist must keep secret every information regarding the state of health of his clients, which was brought to his attention during the exercise of his duties. 4. Every employee is forbidden to reveal information regarding the health of a citizen if this information was acquired by him during the exercise of his duties. 5. The doctor and the pharmacist are not obliged to keep the secret if information is required by them according to the existing legislation. 6. The doctor or the bearers of providing care can give a copy containing medical information on some patient whom they treat, only if this is anticipated by law or by the statute of the bearer. 7. The scientific medical publications must be edited in such a way, so that the patients referred remain anonymous. 8. The doctor and the pharmacist can communicate the result of their research and activities on the condition that the patients related to these remain anonymous. In Monaco, article 308 of the Penal Code anticipates the obligation of keeping the professional secret and Law 975 of 1975 concerning the Civil Servants anticipates that every Civil Servant is bound by the "professional discretion." In Switzerland, there is no Federal Law for the protection of health data. However, the need for such a protection has been recorded in the phase of the preparation of the Federal Law on Statistics. In addition, some of the cantons have laws regarding the data protection. In Luxembourg, the Law of 31.3.79 defines the rules which must govern the data processing. As it concerns the health data the directives are: 1. The personal data banks must have license of operation from the respective ministry. For the issue of this license, conditions of "depersonalization" of data, duration of their storage, restrictions on their communication and techniques for their protection from unauthorized users must hold. 2. The medical data banks must be under the responsibility of a doctor or a pharmacist or a person practicing some paramedical profession. 3. The medical data banks can be used only for the satisfaction of strictly defined purposes. 4. The persons, that information of medical banks regards, have the right of access and the possibility of correction of this information in case of inaccuracies. This access is possible only through a physician. Finally, in Romania, the Code of Penal Laws (article 196) anticipate measures which refer to every kind of professional secret and certainly to the medical one. According to this Law "the unauthorized revealing of certain data which came to the attention of a person during the exercise of his profession and which can damage a citizen, is punished

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by imprisonment" etc. Law 3 of 1978, " o n the improvement of health of the population," part 4, also, anticipates the strict keeping of the professional secret in the area of health.

Protection Anticipated by the Medical Ethics and Deontology Where there is no legislation on health data protection, the secret can be protected by the medical ethics and deontology. In Britain 14'15 the following three basic principles are recognized in the medical profession: 1. It should be considered that the defining information (this, which defines a person) is kept for the specific purpose of the continuous offering of health services to the patient. 2. The access to defining information which is kept in medical files must be restricted to the doctor who gathered it and to the person responsible for the health of the patient. Access from a third person is possible only after permission from the director of the clinic and only if it aims at the clinical interest of the patient. 3. It should not be possible for a person to be identified from data which have been provided for statistical reasons for research or for similar purposes. These data, when provided, presuppose consent of the patient or consent of the committee which is responsible to control the application of the medical deontology. In Ireland, the "Medical Council" published, in 1981, a small book entitled "Statute and Functions: A Guide to the Ethical Conduct and Behaviour and Responsibilities of Practice." One of the functions of the Medical Council is the guidance on all subjects regarding the medical profession and connected to the medical ethics and behavior. The secret of the health data is a basic principle which is preserved from long ago. There are three cases of exemption: 1. When it is required from a court. 2. When there is need for protection of the interests of a patient. 3. When there is need for protection of the society. The medical records must be protected, especially the computerized ones. The following points should be particularly mentioned: 1. The relationship between physician and patient must be always respected. 2. When the conditions allow, the personal doctor of a patient must be updated on possible medical examinations of the patient by third parties. 3. The meaning, rather than the details of medical examinations, should be communicated to third parties, when needed. 4. The documents containing medical details must be communicated and sealed in a proper manner. 5. The physician has the right to deny medical examination of a patient, who does not want to be subjected to it. In Belgium, the "Deontology Code" compiled in 1975 by the "National Council of Doctors," anticipates the secret of the health data. The doctor is responsible for the records he compiles and he decides to which third parties these records can be communicated. In France, the "Code of Medical Deontology" defines that the secret covers all information acquired by the doctor during the exercise of his profession. The doctor is also responsible for keeping the secret of the files regarding his patients.

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In Spain, the "Code of Medical Ethics" is very strict in the keeping of the secret of health data by the doctors. Every medical society has a "committee of (medical) ethics" which is responsible for the infliction of penalties to members who violate the Code, as far as the medical secret is concerned. Finally, in Monaco, the "Code of Deontology" of doctors and pharmacists defines that the professional secret is bounding for these professions, except in cases defined by the law.

Health Data Secret Infliction: Mechanisms and Bodies Responsible In Finland, the report of the Committee on Data Protection anticipates a budget for the establishment of a "Committee on Data Protection" and for the appointment of "Ombudsmen on Data Protection." In Sweden, the National Council of Health has issued special guidelines for the application of the secret on health data. In France, the "National Committee of Informatics and Liberties" has been established by Law 78.17 of the 6.1.78. This Committee should be consulted before the installation of data bases managing citizens' personal data. In Romania, there are disciplinary measures with regard to the violation of the secret on health data. The responsible body is the "Central College of Discipline of Health Professions Personnel" which is operating in parallel to other responsible state bodies as for example the Ministry of Health. In Turkey, the "State Statistical Institute" is responsible for the collection of health data and other statistical data (law 53). The public institutions have the right, under certain conditions, to collect statistical data from a number of institutions related to them. In Britain, the Home Secretary has the responsibility for the protection of data, in general. In Hungary, 13 the Ministry of Health is responsible for the infliction of the Law of Health Services of 1972, which anticipates the obligation of the professional secret for the doctors. In Ireland, the Department of Justice has the whole responsibility of the legislation in the area of data protection. The body responsible for the collection of health data for research purposes is the Medical-Social Research Council. This Council maintains an agreement with the Irish Medical Society, regarding the collection of data which refer to the hospital patients. In Denmark, the health data are collected, sorted, and used by the social authorities by the Ministry of Social Services and by the medical authorities under the Ministry of Interior. According to the Danish law on public authorities' files, a Data Surveillance Authority has been established, consisting of a Council and a Secretariat. In Poland, the protection of all health data is defined by regulations issued by the Ministries of Health and Social Services. In Switzerland, the "Federal Directives" of 16.3.8 t are applied to all administration units under the Federal Government. In Monaco, the health data come from the "Hospital Center Princess Grace" which is a public hospital or from the health personnel, that is, from the doctors, the pharmacists etc. Health data are communicated under the professional secret, to the Official Author-

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ities of the Government which are the "Directorate on Hygiene and Social Action" and the Statistical Service. Only the Government can process and use this information. Finally, in Luxembourg, the collection and sorting of health data is the exclusive responsibility of the "Medical Insurances" of the Organization of Social Security and of the Ministry of Health.

MAIN PROBLEMS Protection of Personal Health Data From what has been presented it is clear that the protection of personal health data is not only the main care and reason of intervention of the public authority a4,ly'Is but the base of the medical deontology, as well. In France, the protection of the individual, as far as his health data are concerned, is secured in two forms, that is, through the professional secret and through the deontological code. In Sweden, the protection of information is obligatory in the Public Health area and refers to the physical condition of the individual, which should not be communicated to third parties, if it is obvious that this communication can harm the individual. The state's care "for the health data and for the personal data of the individual" aims at their secrecy. In particular, the information from a patient about a relative of his, is also kept secret. In Finland, all the basic principles on the protection of health data are concentrating in the protection of the personal data. In Poland, the nursing institutions and the public administration are obliged to use code numbers for the various diseases, reasons of death, statistics, and reports. In this way, the health data are protected because the International Classification of Diseases, Injuries, and Reasons of Death is used. In Hungary, with the development of electronic data processing, the confidential health data of an individual tend to be stored in data bases. Accordingly, the computerized personal health data must be protected to the maximum possible extent and for this purpose the following principles have been established: 1. The health data of a patient are considered secret. 2. The computerized files, regarding a patient, are subjected to official secret and can only be communicated with the permission of the responsible minister. In Turkey, most of the statistical data refer to personal health data and they are protected through disciplinary procedures. In Britain, the personal health data are communicated only through proper authorization or after the given will of the patient himself. In Spain, the law of 28.8.78 secures the secrecy of the personal health data. Access to Medical Data In Sweden, where the general principle is that of free access to all public files, the infliction of restrictions has been considered necessary, as far as the fight of access to personal health data files is concerned. In France, where the general principle is the noncommunication of certain informa-

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tion, administrative measures are in power to facilitate the access to personal health data files under conditions. In Belgium, only the physicians have the right of access to personal health data files, who, in cases of narcotics, alcoholism etc., have the right to collect information without the patient's consent and to store it in data bases. Only physicians and their medical teams have the right to access these data bases. In Britain, the access to personal health data files is governed by the strict medical deontology. In Ireland, where the general principle is that the application by a patient to get information on his health condition should be met positively, relevant application by third parties should be rejected. Accordingly, only the treating doctor and the patient have the possibility of access to personal health data files. In Denmark, the purpose of the "Danish Law on Public Services Files" is to maintain the personal data secret. As far as the health data are concerned, this law anticipates procedures of access to the files, so that the individuality of a patient is completely protected.

Data Communication Historically, the health data communication conflicts with the principle of the professional secret. However, it is generally accepted that for reasons of public interest and in the cases which are specifically referred to in the law, the health data can be communicated or even be made known obligatorily. The birth, the death, and infectious diseases are classical cases of communication and compulsory notification of health data. The use of computer systems in the health area has raised anxieties, as far as the possibility of leakage of data from one data base to another is concerned.

Research The legislation regarding the health data protection is complicated in many cases. As a result, the research which uses health data becomes difficult, because it is related to bureaucratic procedures. Two criteria seem to be generally accepted for the research on health data: 1. Access to health data is allowed only if supervised by an authorized public body. 2. Access to health data is allowed for academic purposes. The two criteria mentioned above are applied in the sense that the identity of a certain individual could not be disclosed. Finally, if participation of a patient is needed, his consent for this research must be given.

HEALTH

INFORMATICIANS'

DEONTOLOGY

CODE (HIDEC)

Prolegomena The HIDEC which follows constitutes the filtrate of the present research. In Greece,16 possible application of HIDEC will lead to include Greek particularities which are not possible to be defined a priori. For what holds in Greece, nowadays, the reader

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should refer to Gritzalis et al. (1991) and The Greek Data Protection Bill (1988), where extensive research is presented. It should be noted though that in Greece there is no legislation on data protection in the health area. The health data are vaguely protected by medical ethics. The HIDEC cannot be static. The evolution of informatics and social systems will be affecting it proportionally. So, there will be a need for continuous revision, so that it is adapted to possible new data. An important remark is that access to the health informatician (h.i.) cannot be excluded from health data which refer to the doctor and his patient.

Individual Professional Deontology Social responsibility. The h.i. uses his specialization for the promotion of health and quality of life. He has moral obligation to assess the social impacts of his activities and to contribute to the safe and beneficial use of the applications of informatics. Protection of the Individuality. The h.i. respects the personality and integrity of the individuals, the groups, and the organizations. He knows that every intrusion to individuality by use of health data, without authorization and consent, constitutes serious and continuous threat of possible exploitation of individuals, groups, and populations. Individual integrity. The h.i. maintains personal integrity of high level, which is fundamental for the harmonious development and fulfillment of the purposes of the health organizations and of the society. The individual integrity includes characteristics which create a feeling of pride to the h.i. Such characteristics are the honesty, the goodness, the objectivity, the sensitivity for the others, and the trust in human relations. He does not cause false impressions, as it regards to the possibilities of abuse of the data processing systems. Professional competence. The h.i. has consciousness of his personal responsibility to maintain and update constantly his technological competence, within the changing domain of information systems which are based on computers. He is aware of the possibilities and restrictions of his specialization in the area of health and in the more general area of data processing as well. Personal responsibility. The h.i. undertakes personal responsibility for whatever he contributes in the domain of health. He undertakes tasks only when there are logical hopes that he will be able to respond to them. During the course of the tasks he undertakes, he provides information to the interested parties. He contributes to the objective control and assessment of the effectiveness of the information systems which he uses, in order to facilitate the attainability of the socially acceptable purposes sought.

Organizational Ethics Standards of High Performance. Given the ample support of the health organization, in which he operates, the h.i. exploits, in full, the resources available to him, in order to achieve internationally recognized standards of high performance, which he expands and specializes to his work. In order to achieve this goal, the h.i. aims also at the interconnection of the health organization he serves, with the proper organizations in the country and abroad.

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Legal Protection. The h.i. respects the national legal frame in which he operates, protecting his work from computer crime. Productivity and quality of working environment. The h.i. creates a working environment of high quality, aiming at the increase of his productivity to the benefit of the health of the society and himself. Users' participation and feedback. The h.i. aims at the maximum possible participation of users, during the design of health information systems, so that the latter enjoy the maximum possible approval. He reconsiders the results of his activities, so that every new design of a health information system required constitutes as improvement over the one already existing. International Legal Ethics International intellectual property. The h.i. respects the regulations of the international rules on intellectual property to the software, hardware, communications and in general to every form of computer products, recognizing these as a consequence of investment in relative scientific and technological creation. However, he maintains the right to put in front the regulations which apply to his specific national environment. International Public Law. The h.i. respects and recognizes, in mutual base, the social obligations which are connected to the health informatics, as these result from the international public law and regard nursing institutions, multinational organizations, supplying companies and social groups. International law on telecommunications. The hS., in the framework of the international law on communication, uses the capabilities of the telecommunications deservingly to the benefit of the society's health. International Penal Law. The h.i. recognizes, according to the international penal law, as crimes in this domain the abuse of the health information systems, the implanting of program-viruses in them, software piracy, software and hardware theft, fraud, and embezzlement through intervention in computers and the sabotage to health information systems.

International Ethics of Public Policy on Health Freedom of Communication of Health Data. The h.i., in mutual base, receives and transmits health data when the improvement of the society's health is served and the individual and social rights are not harmed. Humanitarian Health Information Systems. The h.i. does not use badly designed systems which can lead to damage of the health. The health information systems, which he uses, are well designed and do not affect the humanitarianism, the dignity, and the human rights. International Reference on Health Informatics. The h.i. uses deservingly, to the maximum possible, the international reference on health information systems, contributing also himself to it, with his own knowledge. Equal opportunities in the health informatics' services. The h.i. recognizes the enormous differences between the developed and the underdevelopment countries, as it regards to the health informatics' services and in the measure of his capabilities, he

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contributes with his own initiative or when he is asked by the proper authorities to the efforts of diminution of these differences. Individuality and Human Rights. The h.i. absolutely respects the individuality and the human rights which depend on the use of the health information systems and every act of his results from this respect. Quality of life. The h.i. respects the natural and cultural environment in which he operates and the promotion of the quality of life through health is based on the maintenance of the cultural and natural inheritance.

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Code of Practice, British Computer Society, Handbook No 6, 1983. Data Protection in Britain, Reference Services, Central Office of Information, No 283/86, London, 1986. Data Protection in Medicine, National Health Service Training Authority, United Kingdom, 1987. Evans A., The Data Protection Act, Institute of Personnel Management, United Kingdom, 1985. Griesser, G. (ed.), Data Protection in Health Information Systems: Where Do We Stand? Working conference proceedings, Kiel, 1982. Griesser G. (ed.), Data Protection in Health Information Systems: Considerations and Guidelines. Working conference proceedings, 1987. Gritzalis D., Information Systems Security, Greek Computer Society Publications, 1989 (in Greek). Gritzalis, D., Tomaras A., Katsikas S., Keklikoglou J., Data Security in Medical Information Systems: The Greek Case. Computers and Security, 10(2):141-159, 1991. Hondius F.W., Emerging Data Protection in Europe, North-Holland, 1975. Kuitenhrower F., Legal Aspects of the Use of Information Systems in Health Care. MEDINFO '83, pp. 55-57, North-Holland, 1983. Law of Health Services, Hungary, 1972. The Danish Access to Public Administration Files Act (Act No 572, 19.12), 1985 The Danish Private Registers Act (Publication No 622, 2.10), 1987. The Danish Public Administration Act (Act No 571, 19.12), 1985. The Danish Public Authorities Registers Act (Publication No 621, 2.10, 1987. The Greek Data Protection Bill (draft), 1988 (in Greek). The Hessian Data Protection Act, Wiesbaden, FRG, 1987. The Swedish Data Act, Sweden, 1.1, 1989.