IE Medication Events Implementation Guide - Local Development build (v0.1.0) built by the FHIR (HL7® FHIR® Standard) Build Tools. See the Directory of published versions

Data Minimisation

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 the patient dataset for an ePrescription in EP Section 1, so the ePrescription and eDispensation profiles accept only a patient that carries that dataset:

Profile	Used by	What it carries
Patient (ePrescription)	ePrescription and eDispensation	Only the HIQA EP Section 1 dataset. Everything else is prohibited (0..0)
Patient	administration and medication statements	A permissive base. Sensitive elements are allowed but carry no MustSupport, so no system is obliged to send or process them

What an ePrescription may not carry

Data	ePrescription / eDispensation	Why
Ethnicity	prohibited	Special-category data; not needed to dispense
Mother's maiden or former surnames	prohibited	Identity matching uses the IHI, name, date of birth and address
Nationality, citizenship	prohibited	Not needed to dispense
Place of birth, country of affiliation	prohibited	Not needed to dispense
Religion, marital status, pronouns	prohibited	Not in the HIQA EP dataset
Photo, contacts, multiple-birth indicator	prohibited	Not in the HIQA EP dataset
Sex assigned at birth	required (EP 1.4.3, Mandatory)	Clinically relevant to dosing and contraindications
PPSN	allowed, no MustSupport	The legal basis for health use needs clarification (OI-008)

The traceability matrix lists each prohibited element as Prohibited (enforced).

How it is checked

• Profiles. IEMpdPatientEPrescription sets each prohibited extension slice and element to 0..0. The prescription and dispense profiles only accept that patient profile as their subject.
• Tests. tests/features/data-minimisation.feature checks the profile constraints and every ePrescription patient in the examples, including patients inside ePrescription Bundles.
• Guard script. scripts/qa/check_ep_data_minimisation.py fails the build if any ePrescription or eDispensation example mentions ethnicity, maiden name, nationality, citizenship, religion or marital status.

Identity matching without the mother's maiden name

The HIQA EP dataset carries the IHI (Required), forename and surname, date of birth and address (all Mandatory), so matching relies on the IHI plus these demographics. The IG accepts the IHI in its 18-digit and 10-digit forms (EP 1.3.1; OI-002).