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Confidentiality Codes Refactored. Serafina Versaggi and Kathleen Connor Eversolve. Problem Statement. The current HL7 Confidentiality Code System is overloading the coded attributes of confidentiality Current Confidentiality Codes mix:

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Confidentiality codes refactored

Confidentiality Codes Refactored

Serafina Versaggi and Kathleen Connor

Eversolve


Problem statement
Problem Statement

  • The current HL7 Confidentiality Code System is overloading the coded attributes of confidentiality

  • Current Confidentiality Codes mix:

    • Privacy Policy Codes about how Sensitive Information must be handled with

    • Metadata tags (data about data content) used to convey Information Sender and Receiver responsibilities to prevent unauthorized use or disclosure

  • Without guidance on the intended use of these metadata tags, implementers may mistakenly applying Privacy Policy and Sensitive Information Codes as metadata on protected information

    • On external wrappers used as transport information in exchange

    • On document headers for use by records management systems/repositories

  • As a result, they may be breaching protected information by disclosing the sensitive nature of that information to unauthorized Receivers


Happy news
Happy News

  • Refactored Confidentiality Codes fit seamlessly into the Composite Security and Privacy DAM with minimal changes

  • This should be considered validation of that good work

  • Proposed changes specify

    • Sender responsibility to ensure that protected information is handled in accordance with Privacy Policies

    • Receiver responsibility for handling protected information the Sender is authorized to disclose

    • Interoperable and policy driven Confidentiality Codes that reduce the need for point to point negotiation when exchanging information


Proposed changes to the dam
Proposed Changes to the DAM

  • Refactors current Confidentiality Code System

    • Reason: Multiple Axes that blend internal Privacy Policies with Role and User base Access and interoperable Confidentiality Codes

  • Defines new interoperable Confidentiality Codes

    • Specifies Receiver responsibilities for information being exchanged

    • Limited set of codes that convey general information handling rules

    • Convey sensitivity levels without disclosing why the information is or is not sensitive

  • Relocates Sensitive Information Codes to ActPrivacyPolicyType value set

    • Sensitive Information Codes represent a type of Organizational Privacy Policy

    • Like Jurisdictional Privacy Policies, these are implemented in a Policy Information Point to inform the Policy Decision Point

  • Adds Information Subject Authorization to Disclose

    • Consent Directives - specify disclosures that are more restrictive than generally applicable Jurisdictional Health Privacy Policies

    • Disclosure Authorizations - specify disclosures less restrictive than generally applicable Jurisdictional Health Privacy Policies


Current hl7 confidentiality code concept domains
Current HL7 Confidentiality Code Concept Domains

Current Confidentiality Codes

Relationships


Disambiguating confidentiality and sensitivity
Disambiguating Confidentiality and Sensitivity

  • Definition of these concepts are often intertwined, and usage is not clearly orthogonal in many contexts

  • Healthcare differentiate these because of heightened Privacy concerns

  • Confidentiality is a security concept

    • How information is treated

    • Who can know and what they can do with it

    • Has no necessary bearing on social values

      • ISO 7498-2:1989 - Confidentiality is the property that information is not made available or disclosed to unauthorized individuals, entities, or processes

  • Sensitivity is a social perception concept

    • How information is regarded socially

    • What others will think about and act on the information

    • How that “social” perception and resulting reaction will impact the information subject and/or owner

      • ISO7498-2:1989 - Sensitivity is the characteristic of a resource which implies its value or importance and may include its vulnerability





Vocabulary changes to support use cases
Vocabulary Changes to Support Use Cases

  • Added attribute to Privacy Policy that designates which Privacy Policy

    • May leverage existing HL7 vocabulary Act.code concept domain “ActPrivacyPolicyType”

    • Proposed Vocabulary includes:

      • ActPrivacyLaw – with example codes e.g., 42 CFR Part 2 and HIPAA

      • Sensitivity -

        • Defined as policies shared by a policy domain relating to sensitivity of information

        • Leverages ISO7498-2:1989 definitions for Confidentiality and Sensitivity

        • Example codes from the ConfidentialityModifiers and ConfidentialityByInfoType and proposed codes for Use Case discovered gaps such as Sensitive Service Provider and Employee


Relocated sensitive information codes
Relocated Sensitive Information Codes

Relocates Sensitive Information Codes from AccessByInfoType and Confidentiality Modifiers to the ActPrivacyPolicyType value set

No impact on earlier models which will reference current Confidentiality Code System

No impact on CDA which only uses Normal, Restricted, and Very Restricted

Future models that use ActPrivacyPolicyCodes can target classes with a Comply relationship to an ActClassPolicy





Next steps prepare harmonization proposal
Next Steps – Prepare Harmonization Proposal

  • UPCOMING HARMONIZATION MTGS

  • Harmonization Conference Call

  • Nov 15, 2011 to Nov 18, 2011Add to Outlook Calendar

  • Templates and Examples

  • Download Harmonization Proposal Template/Example

  • Initial Proposals

  • Submissions due 10/16/2011, midnight Eastern

Final Proposals

Submissions due 11/06/2011, midnight Eastern

View/Upload Proposals

View/Upload Proposals

Policy and Procedural Excerpts

Harmonization Process Overview

<http://www.hl7.org/events/harmonization/index.cfm>


Annex
Annex

Compares Current and Proposed Vocabulary

Provides Glossary of Terms


Confidentiality code system definition
Confidentiality Code System Definition

Current Definition of Confidentiality

New Definition of

Confidentiality

Description:

Values that control disclosure of information.

Example: Normal, restricted, substance abuse related.

Definition: The property that information is not made available or disclosed to unauthorized individuals, entities, or processes [ISO 7498-2:1989]

Description: The codes in the Confidentiality code system are values that prevent the unauthorized use of a resource, including the prevention of use of a resource in an unauthorized manner.

The confidentiality code assigned by an information sender (per policies intended by the custodian) that convey receiver obligation to ensure that the information is not made available or redisclosed to unauthorized individuals, entities, or processes (security principals).

The receiver may only grant authorized principals access to the minimum necessary information for the purpose of use intended by the sender. The receiver must grant principals permission to perform approved operations on the information object.





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