Digital Health Space and DMP

What is Digital Health Space (ENS)?

It is a personal and secure digital space that allows each person to access and manage their health related digital data, tools and services. The purpose is to allow the patient to be more involved with his or her health.

Consent to its ENS creation?

Law The digital health space opens automatically, unless the person objects. In other words, consent is not sought before opening a digital health space.

In fact, since January 2022, Health Insurance has sent a letter or email to each approved person informing them of the possibility of benefiting from the digital health space and inviting them within 6 weeks of receiving the mail or email:

  • Either to activate their health space;
  • To oppose its creation.

Individuals can change their mind at any time and close or activate their health space.

What does ENS contain?

The content of the digital health space is defined in the article R. 1111-27 CSP. It contains:

  • Administrative information of its holder (surname, first name, etc.);
  • His shared medical record (DMP);
  • Safe health messages for communicating with healthcare professionals and organizations;
  • Data on health expenditure reimbursement.

By 2022, it will be completed with the following services:

  • Receive reminders for key dates for a health diary and control examinations (check-ups, mammography, immunizations, etc.) to manage medical appointments;
  • A catalog (or store) of applications that integrates digital tools and services specified in the field of health and wellness developed by public or private actors.

Minor and ENS

Can a minor benefit from a digital health space? What will happen to their digital health space as they age?

Health insurance informs the parents with whom the minor is associated about the possibility of enabling or opposing the creation of a digital health space for the minor.

Holders of parental authority perform all actions on behalf of the minor in place of the minor’s digital health. There is no direct entry for minors.

A minor who wishes to keep his or her health condition confidential has the right to request that certain information not be mentioned in his / her digital health space, provided by law (especially regarding contraception, abortion, STI screening).

In its majority, health insurance informs the individual that his or her digital health space will remain open unless he or she objects. Those who have become adults may request closure of their digital health space.

What is the information in DMP?

The DMP, which integrates into the digital health space, includes (Art. R. 1111-42 CSP):

  • Its container identification data;
  • Data on prevention, health and medical, social and medico-social observations, especially vaccines, medical and paramedical summaries, hospitalized contact letters, medical biology reports, medical imaging tests, diagnostic and therapeutic procedures, and prescribed medical data;
  • As a result of the data, reimbursement or coverage method required for the coordination of care, compulsory health insurance is held by the company to which each beneficiary belongs;
  • Drug delivery data, taken from pharmaceutical files;
  • Information about organ or tissue donation;
  • The last advance instructions of life;
  • The identity and contact details of the trusted person;
  • The identity and contact details of relatives notified in an emergency;
  • The identity and contact details of the attending physician;
  • List of professionals, health institutions, organizations or social or medico-social services approved for access to DMP and access granted by the holder.

How is DMP operated?

Healthcare professionals involved in the treatment of DMP holders report the diagnostic and therapeutic components needed to coordinate care in their DMP.

Any professional participant under the supervision of the DMP holder, with prior notice, subject to the consent of the latter, may enter and supply his DMP. Subject to general information from the person feeding the DMP by the same professional (Art. L. 1111-7 CSP)

Holders of DMP can also provide their own health related documents.

This may make some information accessible (art L. 1111-15 CSP, para.)

In terms of patient care, the DMP does not replace the file kept by every health professional, regardless of their practice method, health institution or army hospital.

Who has access to DMP?

Access to DMP is considered reserved or authorized for professionals approved by the patient holding DMP because they are members of the patient care team.

Access to these professionals is limited to data strictly necessary for patient care. The access rights of different health professionals are established according to an authorization matrix associated with their profession or their specialty. Specifically, this means that depending on their profession, a doctor, an ophthalmologist or a pediatrician-pediatrician, for example, is not allowed to access similar documents.

Patients with DMP can change the list of professionals at any time, with access to their file (Art. L. 1111-19 CSP)

The attending physician has the exclusive right to access the patient’s DMP. He can access all the information in the DMP, including the holder’s confidential documents.

All access to the DMP can be found and these traces can be consulted by the DMP holder at any time. The latter, by any means, is informed of the first access to his DMP by a healthcare professional.

Any access outside of the rules mentioned above is invalid and exposes its author to repressive measures by CNIL, but also to criminal proceedings and disciplinary action before a common court.

Who can enter DMP in case of emergency?

Predicted in two cases:

1. Access to the DMP, in case of emergency, of the person unable to express his will by the health professionals. It is intended to allow any healthcare professional to consult the DMP of a patient whose condition poses an immediate risk to his or her health. In the settings, the DMP holder must indicate whether he has granted this access in case of emergency.

2. The holder of DMP must indicate whether he acknowledges that the controlling physician of Samu-Center 15 can consult his DMP during an emergency call about him.

Hosting and data security

How is the data in the digital health space hosted and protected?

The National Health Insurance Fund (CNAM) and the Ministry responsible for health, represented by a ministerial-level representative for digital health, are jointly responsible for data processing within the framework of the digital health space.

According to Article L. 1111-8 of the Public Health Code, data is hosted in France by two sub-contractor companies, Certified Health Data Host (HDS).

  • Worldline, through its subsidiary Santos, relates to shared medical records (DMP) data.
  • Atos related to other data in the digital health space

The Ministry and CNAM, the joint manager of the digital health space, have endorsed and will support at all stages of its design to ensure respect for the rights and freedoms of the National Commission for Computing and Freedom (CNIL). It has already issued a number of comments on its operational text and will be called upon to monitor their implementation.

Data security depends on:

  • National Information Systems Security Agency (ANSSI);
  • Approval of “My Health” in the General Safety Guidelines (RGS).

From the user’s point of view, every activation and every connection to “My Health Space” is subject to a high level of security.

  • For activation, 3 personal identification data verification: temporary code, social security number, Vitale card serial number.
  • For each subsequent connection, enter a username and password, as well as a unique access code received via email or SMS.

Environmental impact assessment of ENS

The Environmental Impact of Digital Health was the subject of a report by the Ministerial Delegation for Digital Health in May 2021, which is accessible here. Click on this link.

Text and reference

Public Health Code:
Articles L. 1111-13 to L. 1111-24 : Digital health space and shared medical records
Articles R. 1111-26 to R.1111-39 : Digital health space, content, creation and access
Articles R. 1111-40 to R.1111-64 : Creation, Content, Terms of Access to DMP and Holder’s RightsHealth insurance
– My health place, a New digital services Private and secure
– My health location: Who can access the data?
– My health location: Terms of service
Shared medical records (DMP) in practice

National Commission for Computing and Liberties (CNIL)
– Digital Health Space (ENS or My Health Space) and Shared Medical Records (DMP): Questions and answers

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