Records & research · NPC advisory opinion
Web-based training accreditation and patient identifiers
Overview
The NPC examined a pulmonary fellowship accreditation platform receiving hospital case details. It distinguished anonymous statistics from pseudonymized records: a retained hospital number could reconnect a record to a patient. For the proposed identifiable transfer, the NPC advised obtaining consent rather than treating it as internal hospital quality management.
Practice implications
Parao Law practice guidance
For physicians
Before entering cases in a training portal, inspect the mandatory fields and ask if an anonymous case summary or hospital verification would satisfy accreditation. Do not assume removing a name makes a hospital-numbered case anonymous. Use only the approved institutional workflow.
For lawyers
Assess who operates the portal, what fields can identify a patient and whether the training purpose differs from clinical care. For the arrangement described, the NPC advised consent; document the basis, disclosures, access controls and deletion or retention terms for the actual system.