Audit trail

Why it matters

Patients trust a health system with their most sensitive information. An audit trail is how an organisation proves that trust is respected and investigates when it is not. The OECD Recommendation on Health Data Governance includes audit among the elements of a national health data governance framework [3].

Key points

• A clinical audit log records reads as well as changes, because most privacy breaches involve viewing a record, not altering it.
• Entries cannot be edited or deleted by users, including administrators.
• Logging deters when it is visibly acted on. In a trial reported in JAMA Network Open in 2022, 4 of 219 staff who received an email warning after unauthorised access repeated it, against 90 of 225 who did not [1].
• Break glass access needs a recorded reason and routine review. A hospital study found justifications left empty and a small number of users accounting for many overrides [2].

In Moana

Moana keeps an audit log of access and changes across the platform, and break glass access is audited with the reason given.

Sources

1. On the spot email interventions reduce repeat medical record snooping incidents by 95%, HIPAA Journal, reporting a JAMA Network Open study, 2022
2. Log analysis of human computer interactions regarding break the glass accesses to genetic reports, ICEIS 2013, SCITEPRESS, 2013
3. Recommendation of the Council on Health Data Governance, OECD, 2016