In the previous article I mentioned that NEHTA had just released a new document entitled “Privacy Blueprint on Unique Healthcare Identifiers - Report on Feedback - Version 1.0 - 14/05/2007”.
A friend of the blog has managed (through considerable diligence) to locate three of the 14 written submissions mentioned in the report and provided detailed comment in the same blog as the first comment. These submissions come from the Office of the Commonwealth Privacy Commissioner (31 Pages), the Australian Privacy Foundation (4 Pages) and the Consumer Health Forum (11 Pages).
These are available on-line and the links to those submissions are as follows:
APF:
http://www.privacy.org.au/Papers/NeHTA_UHI_Blue070313.pdf
OPC:
http://www.privacy.gov.au/publications/subnehtauhi200703_print.html
CHF:
http://www.chf.org.au/Docs/Downloads/430_NeHTA_Privacy_Blueprint_Submission.pdf
Having had a chance to review what these three submissions say, I would suggest it is even more important that all the submissions are made public as it is clear the summary of what was submitted to NEHTA vastly understates the subtlety, number, importance and complexity of what NEHTA has been told.
Readers are asked to download and read for themselves and I am sure they will realise, and agree, just how severely NEHTA’s summary sells the issue very much short.
Given the terrible experience overseas of e-health projects when privacy is not properly addressed NEHTA seems to me to be "burying its head in the sand" over the complexity and difficulty of all this - despite its new found keenness to employ a Privacy Officer.
David.
PS – To answer the question posed in the earlier comment, no, I did not provide a written submission.
D.
5 comments:
Dumbfounded I am, I thought NEHTA was meant to be an 'inclusive' player. This is so so stupid. To invite public comment and then not make the comments available for everyone to read is dumb.
It's worse than dumb, it's insulting. Some of us spent time and resources responding to NEHTA's invitation to comment. We could all learn a lot from the other submissions. There is no reason why they shouldn't be made public. Otherwise one has to assume there is a general lack of openness and a reluctance to accept new ideas and expose current thinking to scrutiny and debate.
If NEHTA seeks to work with its constituents and have them do its bidding and implement its recommendations there needs to be a lot more openness - is that too much to ask?
Some of us spent time and resources responding to NEHTA's invitation to comment. ... There is no reason why they shouldn't be made public.
Why not make them public yourself?
Three of us did but we don't know who the others are.
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