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FRENCH SUPERVISORY AUTHORITY: the CNIL remembers all the principles that need to be respected in order to distribute to doctors the list of no-vaccinated patients

FRENCH SUPERVISORY AUTHORITY: the CNIL remembers all the principles that need to be respected in order to distribute to doctors the list of no-vaccinated patients

The government asks doctors to contact their no-vaccinated patients against COVID by providing them a list of them. The CNIL, as matter of principle adverse to this practice, considers that the exceptional health situation can justify it, but only if doctors require it and if are provided more guarantees in order to protect people’s privacy.

The essential

  • the government desires to conduct a sensibilization campaign for no-vaccinated people by relying on doctors and the National Health Insurance Fund (CNAM).
  • The CNIL remembers also that as a matter of fact it is not favorable to the realization, for doctors, of list of no-vaccinated people.
  • It considers that the health contest can justify the sent to doctors, in a secure way, of the list of their no-vaccinated patients against the COVID-19, but only upon request.
  • It specifies the conditions and guarantees that need to be respected, and in particular the obligation for the doctor to disrupt the list at the end of the sensibilization campaign.
  • It warns on the risk of excessive requests by people, based on those health private data, and it admits the action of the CNAM only if it is complementary to this one of doctors.
  • The CNIL asks to CNAM to privilege its actions with people which have not a doctor.

The governmental project

In a contest in which the vaccination is not mandatory, the Government prevents to realize important sensibilization actions among no-vaccinated people in order to encourage them to vaccinate. These actions are carried out both from doctors with their patients and by the health insurance services.

For this reason, the Government has presented to CNIL a draft decree that authorize the National Health Insurance Fund to modify, from existent storages, the list of no-vaccinated patients part of a doctor, in order that the doctor can contact them. The CNAM is also authorized to use the file “Covid Vaccine” in order to contact no-vaccinated people.

The legislation which is protecting the health confidentiality does not prevent, according to the CNIL, to a doctor to have the access to the vaccination status of their patients, when it is about those people he/she is caring of and the acknowledge of these information is relevant for their care and advice.

At the same time, the CNAM shall have the access to health information on policyholders in order to inform them and make them aware of some procedures provided by the health system.

The CNIL is, as a matter of fact, contrary to the realization, for doctors, of list of their patients according to specific characteristics (vaccinations status, illness, etc.). these lists include personal information which are sensitive and present a risk of abuse. The health operator who access to personal data of his/her patient, and in particular, to his/her health data, only by information that he/she provides to or by the information sources organized by the texts (for example by providential information services or clinical records shared) and in compliance with the health confidentiality.

In addition, the CNIL has underline that these actions, shall be repeated with the same people.

Guarantees required by the CNIL

According to the health crisis which is going on in France, the central role of the vaccination which is carry out in order to fight it, the restricted form of the CNIL considers that some sensibilization actions shall be implemented by mobilizating ways without precedents, but with specific guarantees.

The CNIL therefore accepts the transmission of the list of non-vaccinated patients to the attending doctors, provided in particular that:

  • the transmission takes place, in a safe way, only at the request of the treating doctor, who considers it necessary to educate his patients, and not systematically to all treating doctors;
  • the list is deleted by the doctor at the end of the awareness campaign;
  • the purpose of solicitations is to inform and educate people, and not to try to convince them when they indicate that they do not want to be vaccinated.

The CNIL also considered it necessary to avoid, as far as possible, that the same persons are contacted several times by their doctor and then by the CNAM. It therefore asked that the action of CNAM be only complementary to that of the treating doctors, that is, that it be addressed mainly to people who do not have a treating doctor.



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