The HSE Health App is available to anyone who wants to download it from the Apple App or Google Play stores. However, only people who can categorically prove their own digital identify can access their health data within the App. This is because Health data is categorised as a ‘special category of personal data’ under GDPR and as such, is afforded additional protections under the regulation.
The most cost effective way for the HSE to provide the means for people to prove their digital identify during the ramp up phase of the App is to leverage existing assets that the state has at its disposal. Many people have already gone through the process to prove their physical identify in order to receive MyGov accounts, and the additional steps thereafter to receive a digital identity and understandably would now have an expectation that we use that digital identity wherever and whenever it makes sense to do so.
It is also worth noting that during the development of the Health App, patients expressed the desire to access all of their important health information, regardless of where they were treated. This means the data in the App needs to be able to source data from public bodies (HSE) as well as the voluntary sector (section 38’s and 39’s) and private healthcare providers such as private hospitals, private diagnostic centres, a GPs and community pharmacy. We therefore suggest comparisons with the case in 2019 are not directly comparable and indeed the we have engaged with the Data Protection Commissioners office throughout the development of the Health App to keep them appraised of developments and specifically plans to use MyGovID as a simple means for people to access their health data within the App with the certainty that they – and only they can access it.
We believe this is an approach, of inviting people to use an existing, robust form of digital ID, is sensible and entirely reasonable, cost effective and valid. There is nothing to prevent us from considering other options to complement this approach in the future, especially if individuals object, but would only consider that when the number of users ramps up significantly. It would also require the support of additional state funding.