IE (Ireland) Core Implementation Guide
0.3.0 - draft Ireland flag

IE (Ireland) Core Implementation Guide - Local Development build (v0.3.0) built by the FHIR (HL7® FHIR® Standard) Build Tools. See the Directory of published versions

Data Minimisation

Based on a consultation draft. The datasets below follow the HIQA draft Patient Summary standard (September 2026). This page explains how IE Core applies them. It is not legal advice.

Principle

Under GDPR Article 5(1)(c), personal data must be adequate, relevant and limited to what is necessary. Ethnicity is also special-category data (Article 9). HIQA defines a separate patient dataset for each use case, so each use case has its own patient profile (ADR-002):

Profile Used by What it carries
IE Core Patient every other use case A permissive base. The sensitive elements are allowed but carry no MustSupport, so no system is obliged to send or process them
IE Core Patient (Patient Summary) Patient Summary The HIQA PS Section 1 dataset, including the Required demographics, and a nominated contact person (PS Section 3)
ePrescription patient, in IE Medication Events ePrescription and eDispensation Only the HIQA EP Section 1 dataset; ethnicity, maiden name, nationality and similar data are prohibited (ADR-009)

What the Patient Summary carries

Data Patient Summary Why
Ethnicity Required (PS 1.4.10; CSO Data Standard for Ethnicity v1.0) HIQA requires it for continuity of care; special-category data
Mother's former surnames Required (PS 1.4.6) Identity disambiguation
Nationality, place of birth, country of affiliation Required (PS 1.4.7, 1.4.3, 1.4.8) In the HIQA PS dataset
Religion, marital status, pronouns prohibited Not in the HIQA PS dataset
Sex assigned at birth required (PS 1.4.4) Clinically relevant; recorded separately from administrative gender and gender identity
PPSN allowed, no MustSupport The legal basis for health use is Requires Clarification (OI-008)

The prohibitions are enforced by the profile, so a validator rejects a non-conformant summary. The traceability matrix lists each prohibited element as Prohibited (enforced).

Patient Summary safeguards

The Patient Summary carries the extra demographics because HIQA requires them for continuity of care. HIQA notes that ethnicity is "not used for patient identification" and should be collected with appropriate safeguards. See Security for access control and audit expectations.