The Indonesian Minister of Health has issued Minister of Health Regulation No. 24 of 2022 on Medical Records (“MOH 24/2022”), under which the MOH requires all healthcare facilities to keep electronic medical records. MOH 24/2022 allows, among other things, cooperation between a healthcare facility and a third-party electronic organizer and covers who may have access to electronic medical records.

Electronic medical records are defined as medical records that are made using an electronic system that organizes medical records. Meanwhile, an electronic system is defined as a set of electronic devices and procedures that prepare, collect, process, analyze, store, display, announce, send and/or disseminate electronic information. Electronic medical records are owned by the healthcare facility, but can be managed by a third party electronic organizer. However, the data contained in the records still belongs to the patients of the healthcare facility.