Medical service - Commission
Opinion of 10 September 2007 on the notification for prior checking on the "Management of the activities of the Medical Service in Brussels and Luxembourg, in particular via the SERMED computer application" (Case 2004-232)
The Medical Services in Brussels and Luxembourg use the SERMED database for the day-to-day management of their activities. This database supports the management of medical activities in the fields of preventive and occupational medicine as well as medical check-ups. SERMED can be used to record certain information necessary for the procedures which the Medical Service must carry out: medical examinations, the management of medical absences and check-ups, invalidity procedures and occupational accidents. This information is sorted into lists over a certain period of time (the "reporting" module). As well as SERMED, the Medical Service in Brussels uses another application (DREC) to follow up requests for the reimbursement of additional tests and other medical expenses.
The EDPS concluded in his prior checking that the proposed processing operation does not appear to involve any infringement of the provisions of Regulation (EC) No 45/2001 provided account is taken of the comments made below. In particular, this implies that the Commission:
- having regard to the particularly sensitive nature of the information included in SERMED, should remind persons having access to SERMED of the confidentiality requirement;
- should point out to SERMED users that the field "comment" must contain only administrative data;
- should remove the reference to the doctor's specialisation as indicated on the medical certificate in SERMED;
- should keep the EDPS informed of the introduction of the module facilitating access to information relating to the person concerned.