Emergency access must exist, because a control that obstructs treatment will be
defeated by staff sharing logins. The design goal is usable, unattractive and
loud.
Recorded at the moment of use
who named individual, never a shared emergency account
which patient the specific record, not "a patient"
when grant, first read, last read, expiry
why free-text reason plus a category, entered before entry
scope which record, which categories, which system
duration time-boxed session, typically minutes to an hour
what was seen every item opened within the session, itemised
Reviewed afterwards
by whom someone independent of the user and their line manager,
commonly a Caldicott or privacy function
within a fixed window, typically the next working day
against the reason given, the clinical context, and whether a
legitimate relationship existed but was not recorded
outcomes accepted, query raised with the clinician, or referred
as a potential inappropriate access
informed the patient, on request and in some regimes proactively
Monitored as a metric
invocations per month, per user, per ward
proportion reviewed within the window
proportion resulting in a query
The itemised record of what was seen is the field teams skip and investigators
need. Knowing that someone opened a record does not answer whether they read the
mental health notes, and that distinction is the substance of every complaint
about inappropriate access.
The review is what makes the control acceptable rather than the pre-approval,
because a genuine emergency cannot wait for an approver. Substituting mandatory
independent review after the fact for approval before it is an honest design, and
the fixed window is the part that has to be enforced, since a review backlog
converts the control into logging.
The failure mode to name unprompted is routine use. If break-glass is invoked
hundreds of times a month on a particular ward, it is not emergency access, it is
the access model, and the fix is to make the missing legitimate relationship
visible to the system — bank staff, cross-cover rotas, on-call arrangements —
rather than to keep reviewing exceptions. A rising invocation count is therefore a
design signal rather than a compliance statistic.