On Sun, Nov 05, 2017 at 05:31:50PM +0100, Birger Haarbrandt wrote:

> just a short remark: we were involved in a regional EHR (in the sense of a
> health information exchange network) project in the state of Lower-Saxony,
> Germany. While this might be a different use case, we clearly had to be able 
> to
> physically delete patient data from all IHE XDS repos and registries in the
> case of a patient's withdrawal.

a) The repositories were likely not the primary repositories
   intended for immediate clinical care ?

        in which case the deadlines don't apply

b) had you suspected that a withdrawing patient intends to sue
   the health information exchange network you would likely have
   had the right to retain data regardless

But, yeah, physical deletion certainly seems necessary even
if only, say, 50 years post mortem ...

Karsten
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