Three Rules for Separating Health Data Authentication, Consent, and Access Control
Engineers handling health data should treat login, consent grants, and data access as three distinct decisions rather than collapsing them into a single session-based permission. A consent grant must specify the subject, health data category, purpose, and policy version — not act as a blanket boolean approval for all records. Revocation should immediately affect future reads and trigger a cleanup workflow for derived data, without waiting for any identity-provider migration to complete. A minimal compliant architecture requires four components: an identity adapter, a consent ledger, a policy function, and an audit sink. The design is intended to remain portable across authentication providers, though teams must consult legal counsel to determine jurisdiction-specific consent language and data retention requirements.
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