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Records & research · NPC advisory opinion

Web-based training accreditation and patient identifiers

Reference
Advisory Opinion 2018-056
Date
5 October 2018

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.