Comments on the Proposed Health Data Retention Policy, 2021

Abstract

In this paper we provide our comments on the National Health Authority's proposed Health Data Retention Policy (HDRP). We begin by setting out certain basic principles for design of a health data retention policy, followed by our suggestions pertaining to the specific issues raised in the consultation paper. We focus on the issues of (a) applicability of the HDRP, (b) methods of classification of health records, (c) manner and mode of retention, (d) governance framework, (e) mechanisms for capacity building.

Note:
Funding Information: None

Declaration of Interests: None

Keywords: health data, data retention, government health programmes, data governance, privacy, data protection