JMIR Publications

ABSTRACT

Background:

GDPR was scheduled to be formally adopted in 2016 with EU member states being given two years to implement it (May 2018). Given the sensitive nature of the personal data that healthcare organization process on a 24/7 basis, it is critical that the protection of that data in a hospital environment is given the high priority that data protection legislation (GDPR) requires.

Objective:

This study addresses the state of Public Portuguese hospitals regarding GDPR compliance in the moment of GDPR preparation period (2016-2018) before the enforcement in 25 May 2018, and what activities have started since then. The study focuses in three GDPR articles namely 5, 25 and 32, concerning authentication security, identity management processes and audit trail themes.

Methods:

The study was conducted between 2017 and 2019 in five Portuguese Public Hospitals (each different in complexity). In each hospital, six categories of information systems critical to health institutions were included in the study, trying to cover the main health information systems available and common to hospitals (ADT, EPR, PMS, RIS, LIS and DSS). It was conducted interviews in two phases (before and after GDPR enforcement) with the objective to identify the maturity of information systems of each hospital regarding authentication security, identity management processes and traceability and efforts in progress to avoid security issues.

Results:

A total of 5 hospitals were included in this study and the results of this study highlight the hospitals privacy maturity, in general, the hospitals studied where very far from complying with the security measures selected (before May 2018). Session account lock and password history policy were the poorest issues, and, on the other hand, store encrypted passwords was the best issue. With the enforcement of GDPR these hospitals started a set of initiatives to fill this gap, this is made specifically for means of making the whole process as transparent and trustworthy as possible and trying to avoid the huge fines.

Conclusions:

We are still very far from having GDPR compliant systems and Institutions efforts are being done. The first step to align an organization with GDPR should be an initial audit of all system. This work collaborates with the initial security audit of the hospitals that belong to this study.