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How should FHIR Consent be used in Norway?

In Norwegian legal provisions there is a concept of informed consent ("informert samtykke") which is a consent that includes, among other rights, the right to access patient's EHR/journal (jf. https://lovdata.no/lov/1999-07-02-63/§4-1).

This consent is not registered explicitly as a consent in DIPS Arena EHR, but is nevertheless a real consent. The question is whether this should manifest itself as a FHIR Consent or not? I believe not, since it is the default. Comments on that?

Then we have the exceptions to the default consent. This may be negativ consents (deny) or positive consents (permit). This is the type of consents that definitely will manifest itself as FHIR Consent(s) instances.

In DIPS EHR we have two types of consents:

  1. Reservations (negative consents / deny ) - blocking or reservation against accessing certain pasient information for specific persons, groups or everybody
  2. Exemptions (positive consents / permit) - exemptions which overrides previously active reservations.

There may be serveral reservations and exemptions active at the same time. The easiest way to model this is that each reservation / excemption is represented by its own FHIR Consent instance. The consumer will have to process the list of reservations and exemptions to determine if a person (e.g. health personell) has access to particular patient information requested. Comments on that?

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