CH EPR FHIR (R4)
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This page is part of the CH EPR FHIR (R4) (v4.0.1-ballot-2: DSTU 4 Ballot 3) based on FHIR (HL7® FHIR® Standard) R4. This is the current published version in its permanent home (it will always be available at this URL). For a full list of available versions, see the Directory of published versions

Privacy Policy Query for Mobile (CH:PPQm)

Scope

According to Swiss EPR regulations, patients shall decide who is authorized to view the documents and data in their EPR, and under which circumstances (cf. emergency access). The national integration profile "Privacy Policy Query" (CH:PPQ, see Amendment 2.1 of Annex 5 EPRO-FDHA) defines how this decisions are transmitted as patient privacy policies in XACML 2.0 format and the SOAP transport protocol. This profile offers the same functionality based on lightweight HL7 FHIR® resources and RESTFul transactions.

Use Cases

EPR Onboarding

A patient contacts a community to open an EHR in the community. The patient passes the identification process of the community and consents to the EHR. The policy administrator of the community documents the patient consent by adding the patient policies to the policy repository.

The policy administrator of the community adds the following patient privacy policies to the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

When both of the above policies are stored in the policy repository of the community, healthcare professionals upload all new treatment documents to the patients EHR with the confidentiality set as the default confidentiality level, or higher.

Patient authorizes a healthcare professional

A patient wants to authorize a healthcare professional to access the patients EHR and to view the documents on a specific access level. The patient authenticates in the patient portal and opens the view to the access policy settings. The patient opens the form to authorize an individual healthcare professional and searches for the healthcare professional entry. The patient selects the healthcare professional to be authorized, optionally sets an authorization end date and selects whether the healthcare professional is also authorized to delegate the access rights.

To authorize the healthcare professional, the patient portal adds the following policies to the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

Patient authorizes a group of healthcare professionals

A patient wants to authorize a group of healthcare professionals to access the patients EHR and to view the documents on a specific access level. The patient authenticates in the patient portal and opens the view to the access policy settings. The patient opens the form to authorize groups and searches for the group entry. The patient selects the group to be authorized and sets an authorization end date.

To authorize the group of healthcare professionals, the patient portal adds the following patient private policy to the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

Patient updates the default confidentiality level

A patient wants to enforce, that all documents stored in the EHR are stored with a minimal confidentiality level. The patient authenticates in the patient portal and opens the view to the default confidentiality level settings. The patient sets the default confidentiality level in a form provided by the patient portal.

To set the default confidentiality level, the patient portal updates the following patient privacy policy in the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

Patient changes the emergency access setting

A patient wants to change the current setting of the emergency access, which grants all healthcare professionals access to the EHR in a emergency situation. The patient authenticates in the patient portal and opens the view of the emergency access setting. The patient disallows emergency access or sets the maximum confidentiality level of documents accessible in emergency situations in the form of the emergency settings.

To disallow or allow emergency access of documents up to a confidentiality level, the patient portal deletes or updates the following policy in the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

Healthcare professional delegates the access rights

A healthcare professional previously authorized by the patient to delegate access rights (e.g., substitution during holidays, second opinions), delegates the access rights to another healthcare professional. The healthcare professional authenticates in the portal or primary system and opens the view with the delegation settings. The healthcare opens the form to change the delegation settings and searches for the healthcare professional to delegate the access rights to. The healthcare professional selects the healthcare professional entry to be authorized and optionally sets a delegation end date.

To delegate the access rights, the portal or primary system adds or updates the following policy in the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

Policy Administrator sets a patient representative

A policy administrator of the home community intends to set a person as a patient representative. The policy administrator authenticates to the portal and selects the view of patient representatives. The policy administrator opens the form to add a representative for the patient and enters the required data.

To add the person as patient representative, the portal adds the following policy in the policy repository with the Mobile Privacy Policy Feed (PPQ-3) or Mobile Privacy Policy Bundle Feed (PPQ-4) transaction:

Actors and Transactions

CH:PPQm comprises the following actors and transactions:

CH:PPQm actor diagram
Figure 1: CH:PPQm actor diagram

Actor: Policy Repository
Role: Stores policies and policy sets and provides the possibility to add, query, update and delete them
Actor: Policy Source
Role: Initiates addition, update and deletion of policies and policy sets
Actor: Policy Consumer
Role: Retrieves policies and policy sets

Table 1 lists the transactions for each actor directly involved in the CH:PPQm Profile. To claim compliance with this profile, an actor shall support all required transactions (labeled "R") and may support the optional transactions (labeled "O").

Actors Transactions Optionality Section
Policy Repository Mobile Privacy Policy Feed (PPQ-3) R PPQ-3
  Mobile Privacy Policy Bundle Feed (PPQ-4) R PPQ-4
  Mobile Privacy Policy Retrieve (PPQ-5) R PPQ-5
Policy Source Mobile Privacy Policy Feed (PPQ-3) O (Note 1) PPQ-3
  Mobile Privacy Policy Bundle Feed (PPQ-4) O (Note 1) PPQ-4
Policy Consumer Mobile Privacy Policy Retrieve (PPQ-5) R PPQ-5

Table 1: CH:PPQm transactions

Note 1: The actor SHALL support at least one transaction.

The required actor groupings are shown in Table 2:

Actors Actor to be grouped with
Policy Repository IUA Resource Server
  ATNA Secure Application
Policy Source IUA Authorization Client
  ATNA Secure Application
Policy Consumer IUA Authorization Client
  ATNA Secure Application

Table 2: CH:PPQm required actors groupings

Referenced Standards

See also:

Relation between CH:PPQm and CH:PPQ

This section is not normative.

Implementers may decide to implement CH:PPQm transactions on top of CH:PPQ ones, i.e. to create a FHIR layer over an existing XACML-based Policy Repository. The CH:PPQm specification supports this approach by defining transactions and data structures in a way which allows an efficient bridging between CH:PPQ and CH:PPQm, and by providing message transformation rules (see the page Mappings).

In terms of actor grouping, this would mean that the Policy Repository may be optionally grouped with CH:PPQ Policy Source and CH:PPQ Policy Consumer in order to communicate over PPQ-1 and PPQ-2 with itself.

Note that CH:PPQm is not intended to handle base policies and policy sets, i.e. the ones provided in the official Policy Stack and not related to any particular patients.

Further Aspects

In order to provide interoperability between CH:PPQ and CH:PPQm, the page Mappings defines transformation rules between XACML 2.0 Policy Sets and PpqmConsent resources.