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Records & research · NPC advisory opinion

Resident case logs for specialty accreditation

Reference
Advisory Opinion 2018-016
Date
12 April 2018

Overview

A hospital asked whether resident physicians could send identifiable case logs to specialty societies for board examination or accreditation. The NPC advised consent for the proposed disclosure and suggested hospital certification of case counts or genuinely anonymous data instead. Replacing names with codes is not necessarily anonymization when patients can still be identified.

Practice implications

Parao Law practice guidance

For physicians

Plan the external case-log format before cases are collected. Ask whether the society needs patient names, hospital numbers and dates or merely verified experience. Use a hospital-approved certification or genuinely anonymous summary where it meets the requirement; do not export a patient list from the chart by default.

For lawyers

Review the society’s exact fields and the hospital’s authority for disclosure. If identifiable information is needed, design a specific consent and controlled transfer. Treat coded records as personal data if a key or combination of fields still allows identification.