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Is breaching patient confidentiality ever justifiable?

A cluster of AIDS cases in Cornwall has prompted calls for a person allegedly linked to the outbreak to be named. But is breaching a patient's confidentiality ever justifiable, even if it's in the interests of public health? Mark Stephens, head of media at Finers Stephens Innocent and Dr Stephanie Bown, a legally qualified doctor at the Medical Protection Society, discuss the issues with Veronica Cowan...

The surf’s up in St Ives, the Cornish resort, along with anxiety levels about an AIDS scare. A cluster of up to ten cases led West Cornwall Primary Care Trust to warn earlier this month that heterosexual men and women – with a risky sexual history, between the ages of 20 and 50, could be at risk. The Trust was under pressure to name a man after media reports that it had said there were "some links to a person", but Dr David Miles, director of public health at the Trust, denies this was said, although he did not rule out a link with an individual.  

Confidentiality is a fundamental ethical principle in health care and doctors can be in a tricky situation, because naming an individual patient without consent would breach patient confidentiality, and disciplinary proceedings, and court action, could follow. In cases of “serious communicable diseases” disclosure to sexual partners may be permitted, and in exceptional circumstances disclosure to a public authority like the police may be justified, said a spokeswoman for the General Medical Council. But she added: “I cannot imagine any circumstances in which a doctor could tell the media, without the patient’s consent”, and a doctor would have to be prepared to justify his or her actions later."  

So is this too restrictive where public safety is involved? A spokesman for the Terrence Higgins Trust does not think it is when it comes to HIV: “There is a nervousness about being identified, because of a fear of prosecution, which is on the increase. There is also a stigma around HIV.” Dr. Miles does not perceive the rule on confidentially as being a handicap to  practitioners like himself, and observed: “We can work with it.”

So what are the legal issues? Revealing medical records would be a criminal offence under the Data Protection Act 1998, although the CPS would have to demonstrate a public interest in any decision to prosecute, according to Mark Stephens, head of media at Finers Stephens Innocent.  On the civil law front, a patient at risk of being named could get an injunction to prevent this. ”If a patient has already been identified, he could claim his medical privacy had been invaded,” comments Stephens, adding: “That is actionable in damages, although there is a public interest defence, the success of which would depend on how promiscuous the man had been, and whether he had endangered third parties.” A defamation action could also follow disclosure, although correct identification would raise the defence of justification, he said.

Dr Stephanie Bown, a legally qualified doctor at the Medical Protection Society, observed that clinicians regularly have to balance individual rights of confidentiality against wider interests of public safety. “The information on HIV would be considered highly sensitive but benefits in disclosure would enable people to protect themselves from serious harm or death.  In deciding whether to breach confidence clinicians would need to be confident of correct identification, try all other steps to prevent individuals exposing others to risk, and be able to demonstrate that this was done if there was a complaint to the GMC.”  Noting that there could be a public interest in disclosing to a well defined group, she gave the example of a case where photographs were put up in nightclubs – a targeted disclosure – to protect people from an individual.

The other side of the coin, observes Bown, is that if clinicians do nothing and a victim, who contracts HIV from the infected person, takes the view that insufficient steps were taken to alert him or her, the victim may be able to bring an action in negligence if they can demonstrate it was reasonably foreseeable they would be harmed.

She concluded that doctors would be well advised to contact their medical protection organisation to get advice in cases like this. “The important thing is to put themselves in the best position to rebut a challenge, by showing everything is documented and that they have taken advice from other professionals.”

  (23/05/06)

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Legislative annotations in other services:-
Data Protection Act 1998