The German Psychotherapists Network (DPNW) has sharply criticized the current draft of the Medical Register Act. According to the DPNW, this draft could allow the processing of sensitive health data without the active consent of those affected. This would jeopardize the “maintenance of genuine informed consent” and reinforce the trend towards opt-out solutions, such as with the electronic patient file (ePA).
“Many citizens already struggle to understand which health data is stored, linked, or evaluated where,” stated the DPNW. The organization emphasizes that a mere opt-out solution is insufficient to ensure privacy protection for psychotherapeutic data.
The draft goes “far beyond traditional research registers” and lays the groundwork for a more comprehensive consolidation and evaluation of sensitive health data. Psychotherapeutic treatments often address intimate topics such as trauma and family conflicts, which could jeopardize the trust between patients and providers.
Susanne Berwanger, Vice President of the Association of German Psychologists, warned that a loosening of confidentiality could lead patients to be more critical of treatment. This could reduce the chances of help for those with mental health issues.
Therefore, the DPNW demands that psychotherapeutic data not be linked across registers. Critics view the planned changes as a health policy development towards an increasingly extensive use of health data for research and quality assurance.
