A health record is a collection of health data about an individual, prepared in connection with treatment or acquired from elsewhere in connection with treatment at a healthcare institution or the premises of a self-employed healthcare professional.
Health records should include descriptions, interpretations, or other information, whether in paper or digital format. This includes imaging, test results, any visual materials, audio and video recordings, research data, and other essential personal information related to a patient's health and their treatment by healthcare professionals or institutions.
A health record is stored in the health information system of healthcare facilities or on the premises of self-employed healthcare practitioners. These parties are the guardians of the health records. The supervisor of health records is a physician or another healthcare practitioner, if no physician is available, appointed by the guardian to supervise the entry and handling of information in health records and to ensure that they are consistent with the provisions of the Health Records Act. Healthcare practitioners who work alone on their premises are deemed to be the supervisors of health records they enters.
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A patient or their representative has the right to obtain a copy of their health record, in whole or in part.
Such a request shall be made to the health records supervisor. The supervisor must comply with patients' requests for copies of their medical records without undue delay.
In the case of health data acquired from sources other than the patient themself or healthcare practitioners, the consent of the source of the information shall be elicited before the record is shown to the patient. Should such a source of information on a patient be deceased, or refuse on unreasonable grounds to give consent, the Medical Director of Health may decide that the patient or their representative be granted access to the data in question, in whole or in part. (This provision will be amended on December 1, 2026)
A patient is entitled to information from the health records supervisor regarding which people have gathered information from their health record, where and when the data were collected, and for what purpose.
Amendments to the Health Records Act were approved by Althingi on 19 November 2025. The amendments include the following changes:
The guardian of a health record is allowed to delegate the copying of health record data to another party
The patient covers the cost of copying the documents.
The Minister establishes, through a fee schedule, the cost for reviewing a health record before handover and for copying the health record data provided in accordance with the Health Records Act.
If it is foreseeable that the cost of reviewing health records and copying, including digital data, will exceed ISK 10,000, it is permitted to request advance payment.
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The guardian of health records may provide a copy of the deceased's health record to a close relative, such as a spouse, parent, or descendant, if there are compelling reasons. When deciding whether to release a copy of the health record of a deceased person, the interests of the requesting relative should be weighed alongside the wishes of the deceased, if such information is available.
A request for a copy of the deceased person's health record should be sent to the supervisor of the health records where the deceased received care.
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Healthcare practitioners who are involved in a patient’s treatment and require their health records in connection with the treatment shall have access to the patient’s health records, with the restrictions arising from the provisions of the Health Records Act.
Health records contain sensitive personal information and are confidential. All healthcare practitioners must maintain confidentiality about all the matters stated in health records. The duty of confidentiality persists after the death of a patient and after cessation of the practitioner’s employment.
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If a patient is denied a copy of their health record in whole or in part, they have the right to appeal the denial to the Directorate of Health.
The same applies to refusals by the guardian of health records to provide a close relative with a copy of a deceased individual's health record. The case processing shall be in accordance with the Administrative Procedure Act.
Decisions of the Medical Director of Health on access to health records are final at the administrative level and may not be appealed to the Minister.