A written records policy, and each record holding a unique identifier, name, sex, date of birth, address, phone, drug allergies, consultation notes, investigations, treatment, and sick leave or referral records. Personal data is handled under the PDPO, and eHealth is moving toward required deposits.
What the Code lists
The Code of Practice for Clinics requires a medical records policy and sets out what each record holds. It also asks staff to have due regard to the Personal Data (Privacy) Ordinance.1
The Electronic Health Record Sharing System (Amendment) Ordinance 2025 took effect on 1 December 2025 and renamed Cap. 625 the Electronic Health System Ordinance, with power to require specified providers to deposit specified data.2 The details are to be set in subsidiary legislation later, so check before treating deposits as required.
- Write the policy. What a record holds, who can see it, how long it is kept.
- Capture at the visit. Notes, investigations, treatment and referrals, signed.
- Record allergies first. Before anything is prescribed.
- Control access. By role, with a log.
- What each record holds ______
- Who can access, by role ______
- Where records are hosted ______
- How long they are kept ______
- eHealth status ______
Questions
Must clinics deposit records in eHealth?
The 2025 amendment gives power to require it, with details to come in subsidiary legislation. Not yet required for private clinics as of October 2026.
Which privacy law applies?
The Personal Data (Privacy) Ordinance, Cap. 486.
How fast are sentinel events reported?
Within 24 hours, to the Director of Health.
Sources
- 1Department of Health, 2026Code of Practice for Clinics, 2026 edition, PHF(E) 31ARead source
- 2eHealth, 2025The Electronic Health Record Sharing System (Amendment) Ordinance 2025Read source
Written by the wai team from Office for Regulation of Private Healthcare Facilities, Department of Health, Hong Kong guidance, checked on 15 October 2026. This is guidance, not legal advice. ORPHF does not endorse wai or any software.