Compliance for multi-professional health centers (MSP)
Sharing the patient record among an MSP’s professionals is at the heart of the care project — and can amount, depending on the patient base and how exchanges are organized, to large-scale processing of health data that engages the organization itself. Certified information system, access rights, patient information: compliance underpins serene coordinated practice.
What the regulations require of you
Each obligation is cited with its legal reference — so you know exactly where it comes from and what it demands of your organization.
Frame sharing within the care team
Within the care team, sharing the information needed for care relies on informing the patient and their absence of objection; outside the care team, their consent is required.
Appoint a DPO
Patient monitoring at the scale of an MSP generally constitutes large-scale processing of health data — a criterion which, when met, makes the appointment mandatory.
Carry out a DPIA
Large-scale processing of health data is among the cases where an impact assessment is required before processing begins, in line with the list published by the CNIL.
Keep the organization's record of processing
Shared record, scheduling, billing, HR: the MSP documents its processing in its own record, distinct from those of the professionals for their individual practice.
Secure the IT system and access rights
Profile-based access, audit trails, backups — and HDS-certified hosting whenever health data is hosted by a third party.
What is at stake for your organization
- Frame the sharing of the patient record among professionals (scope of the care team, consent where applicable).
- Secure the information system (e-health labeling, HDS hosting, access rights).
- Appoint a DPO: an MSP processing health data on a large scale is in principle required to do so.
- Formalize the record of processing, information notices and rights-handling procedures.
- Prepare the organization for a CNIL inspection.
What triggers the need
- Installing or replacing the shared information system
- A new professional joining and the opening of their access rights
- A patient requesting access to their record
- A labeling process or an institutional visit
Sound familiar? Now is the right time to get the subject under control — before it takes control on its own.
The most common mistake
Believing that the software vendor “handles the GDPR”. The vendor is a processor: the MSP remains responsible for the processing, for informing patients and for access rights — and it is the MSP the authority questions.
What we put in place
- Full compliance programme for health-information sharing
- Shared outsourced DPO, designated with the CNIL for the organization
- Audit of the information system and data hosting
- Patient information templates and rights management
- Training for the multi-professional team
Expertise backed by the NELSE technology
MSP: our support relies on the tools developed by NELSE: each processing activity is qualified by written, sourced legal rules, the register stays up to date version after version, and the files handed over can be verified by a third party. The DPO assesses, advises and documents their opinions; your organisation keeps its decisions.
In practice, for you: the patient record shared between partners and online appointment booking are qualified separately: for each, you know whether an impact assessment is required, and the periodic review of each record is scheduled, not left to memory.
Discover our softwareYour questions
Must an MSP appoint a DPO?
In most cases, yes: patient monitoring at the scale of an MSP generally amounts to large-scale processing of health data — a criterion which, when met, makes appointing a DPO mandatory. We qualify your situation during a first call; a shared outsourced DPO is often the best-suited solution.
Can the DPO be shared between several organizations?
Yes. The GDPR allows independent organizations to use the same external officer under a service contract (Article 37(6)), provided they remain reachable and effectively able to perform their tasks for each of them. That is precisely our model: a health-specialized DPO, designated for your organization.
Is the patient’s consent required to share their record?
Within a care team as defined by the French Public Health Code, sharing the information needed for care relies on informing the patient and on their absence of objection; outside the care team, their consent is required. We define these scopes precisely with you.
Let’s secure the compliance of your organization
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