Legal frameworks

For archiving and distributing medical data exists a legal set of rules, that precisely specifies the requirements. marc fulfills the current requirements and also commits to meet future standards.

TitleReferenceDateLink
ELGA Ordinance 2015BGBl. II Nr. 106/201512.05.2015Link
ELGA Ordinance Amendment 2019BGBl. II Nr. 54/201926.02.2019Link
eHealth Regulation (eHealthV)BGBl. II Nr. 449/202016.10.2020Link
eHealth Regulation Amendment HPVBGBl. II Nr. 53/202324.02.2023Link
Data Protection Adaptation Act 2018BGBl. I Nr. 62/201612.05.2017Link
Signature and Confidential Service Ordinance (SVV)BGBl. II Nr. 208/201601.08.2016Link
Telematic Health Regulations 2013 (GTelV 2013)BGBl. II Nr. 506/201316.11.2022Link
Changes of the agreement in accordance with Article 15a B-VGBGBl. I Nr. 199/201315.10.2013Link
Changes of the Signature Regulation 2008BGBl. II Nr. 401/201009.12.2010Link
Changes to the E-Government Act (E-GovG-Amendment-2007)BGBl. I Nr. 7/200807.01.2008Link
Federal Law on Adapting LegislationBGBl. I Nr. 101/200728.12.2007Link
Information Security Act (InfoSiG)idF BGBl. I Nr. 23/2002, 129/2003, 10/2006, 32/201815.01.2002, 30.12.2003, 13.01.2006, 17.05.2018Link
Signature and Confidential Services ActidF BGBl. I Nr. 50/201608.07.2016Link
Professional Right-Amending Law for Notaries, Lawyers and Civil Engineers 2006 (BRÄG 2006)BGBl. I Nr. 164/200530.12.2005Link
Supplementary Register Regulation (ERegV)BGBl. II Nr. 241/200501.08.2005Link
Delivery Service Regulation (ZustDV)BGBl. II Nr. 233/200528.07.2005Link
Address Register Regulation (AdrRegV)BGBl. II Nr. 218/200520.07.2005Link
Amendment to the Data Protection Act 2000 (DSG 2000)BGBl. I Nr. 13/200531.03.2005Link
Register of Ordinances Regulation 2009 (StZRegBehV 2009)BGBl. II Nr. 330/200912.10.2009Link
Health Reform Act 2005BGBl. I Nr. 179/200430.12.2004Link
E-Government Area Segregation Regulation (E-Gov-BerAbgrV)BGBl. II Nr. 289/2004, 213/201315.07.2004, 15.11.2022Link
E-Government Act (E-GovG)BGBl. I Nr. 10/200427.02.2004Link
583. Regulation: Requirements for electronically transmitted invoicesBGBl. II Nr. 583/200323.12.2003Link
Information Security Regulation (InfoSiV)BGBl. II Nr. 548/2003, 67/2012, 131/2018, 268/202228.11.2003, 14.03.2012, 20.06.2018, 06.07.2022Link
Commission Implementing Decision laying down standards(EU) 2016/65025.04.2016Link
EU Directive - Requirements for accounting2006/112/EG01.07.2022Link
31. Regulation: Suitability of A-SIT as confirmation bodyBGBl. II Nr. 31/200002.02.2000Link
EU Regulation on electronic identification and trust servicesNr. 910/201417.09.2014Link
Judgment of the Supreme Court on the obligation to provide documentationOGH 8 Ob 134/01 s16.08.2001Link

The storage of X-ray images

The Federal Ministry for Social Security and Generations has informed the Austrian Medical Association about the legal regulations for the storage of radiographs:

Question 1: Do X-rays fall under the ten-year retention period of Section 51 (3) of the Doctors' Act 1998 or are they to be kept for thirty years?

X-ray images are in accordance with § 51 Abs. 3 Ärztegesetz 1998. BGBl. I No. 169, other, the documentation in the sense of § 51 Abs. 1 leg.cit. relevant documents and therefore in accordance with § 51 Abs. 3 leg.cit. ten years from the end of treatment.

Question 2: Can a physician take radiographs to patients or other physicians, or does he have to keep them by himself and can only pass copies?

As a result of an interpretation of the legal interests or interests between the physician's obligation to keep the patient and the patient's health, the obligation to retain the right to rescind has to be withdrawn.

The answer to the question depends on who can be regarded as the owner of the X-ray images.

On the basis of the opinion obtained and with reference to relevant literature and jurisprudence, a differentiated view is held by the health department. The content of the treatment contract is decisive.

If the production of radiographs is agreed upon, as is customary in medical radiology diagnostics, the patient becomes the owner of the X-ray image as a result of the treatment contract, which is then largely to be qualified as a contract for work, with the result that the patient must be handed over the original on the basis of his civil law claim.

If, on the other hand, the production of an x-ray image is merely ancillary to a treatment contract, the doctor or health care provider remains the owner of the X-ray image. It is to be considered, for example, to the X-ray image of dentists.

In the last-mentioned constellation, the patient's right of access, which is deduced from the nature of the treatment contract as a secondary obligation, and which is also anchored in hospital and physician rights applies.

It also includes at least the patient's right to request copies of his documentation. The cost of these copies is borne by the patient. If the technical possibilities for this are not available, the physician is obliged to surrender the original, taking into account the above-mentioned balancing of legal interests.

Question 3: Is a so-called 'takeover' declaration necessary or is it sufficient with this retention obligation?

Since there are no special formal requirements, there is no need for a separate declaration of acceptance, even though this can certainly be useful for the purpose of proof-of-preservation. However, a corresponding note must be made in the patient's medical history.

Question 4: What doctor must keep the X-ray image when several physicians are involved?

There are no explicit legal provisions, even if it would be sensible that every physician treating a radiograph had a radiograph. However, this will be virtually impossible, since copies will incur additional costs and will not be available in any case.

It is recommended that the doctor in charge of the last treatment keep the X-ray image, and the other doctors in the patient's health record where the radiograph is.