Medical record retention, Code of Medical Ethics, Law 3418/2005 Article 14
A legal minimum of 10 years for private practices, 20 years for clinics, the strictest explicit retention floor of any sector we serve.
Clinics & Practices
Compliance for clinics and medical practices
Healthcare carries the densest overlapping digital obligations, and the longest hard legal minimum for record retention.
Separate assessment for medical systems
Medical practices, clinics, and electronic medical-record systems are reviewed case by case. We do not present the service as a turnkey compliance solution for medical environments; scope and appropriate measures are agreed in writing before any activation.
Legislation
Your obligations
Individual Electronic Health Record (ΑΗΦΥ), Law 4600/2019 Article 84
Requires every doctor keeping a patient file to log examination data in the ΑΗΦΥ. Provides for criminal penalties of up to 10 years' imprisonment and €50,000 for unlawful access.
Special category data, GDPR Article 9
Health data requires enhanced safeguards beyond ordinary personal data.
E-prescribing, Law 3892/2010, Law 4600/2019 Article 90, Law 4812/2021 Article 78
Mandatory for doctors and pharmacies contracted with insurance funds, extended to narcotics and the Electronic Narcotics Register.
Recovery design
Clinical continuity, not a file copy
In healthcare, restore order affects care: the record, images, and results must return coherently and only to the right users.
A consistent medical-record database
The EMR database, attachments, and metadata should not be copied piecemeal. The application needs a supported backup method and an isolated restore test.
Imaging and laboratory results
DICOM studies, device exports, and test results may sit outside the main record. Each source is mapped separately together with how it links back to the patient.
Priority and controlled access
Active patients, appointment schedules, and critical results need an agreed restore order. Post-recovery access must preserve roles and audit records.
Enforcement
Recent enforcement
Three cases that show exactly what the Hellenic DPA checks in your sector:
Hellenic DPA Decision 36/2022, €30,000
Fine against a diagnostic centre for losing mammography images, the device only kept them locally for three months. Exactly the failure managed backup prevents.
Hellenic DPA Decision 11/2025, €5,000
Fine against an IVF/maternity doctor for unauthorised access to a former patient's electronic record.
Hellenic DPA Decision 37/2024, €15,000
Fine against a doctor for using hospital patients' phone numbers in a political SMS campaign.
Practical answers
Questions from clinics & practices
Is the medical application's database covered automatically?
No. The standard service covers agreed files and folders. A medical application's database needs a separate assessment with its supplier or technician so that the backup is consistent and the recovery procedure can be verified.
How can a restore be tested without exposing health data?
Define the smallest necessary sample, limit participants, and use a controlled destination. Record whether the agreed files were restored and opened correctly without copying sensitive data into a general shared area or unnecessarily widening access.
Should images, clinical notes, and administrative records have the same recovery priority?
Not necessarily. Clinical continuity may require active histories and recent examinations first, while financial or older administrative records can follow. Categories, recovery timing, and permissions are agreed in writing after the actual system is assessed.
The Fix
How ArvaSafe covers this
- Medical systems and special-category data require a separate technical, contractual, and privacy assessment before activation
- Exact scope, data categories, and retention period are defined in writing in the Order Form
- Any immutability and restore test apply only as agreed in writing
- ArvaSafe documents only the controls of the service actually agreed
Sources
Official references
Related professions
Compare documentation and recovery needs
Each profession has a different working file, access model, and recovery order.
Accounting FirmsLaw 5104/2024, myDATA, e-invoicing, and when retention beyond the five-year floor may be appropriate.NotariesPaper registers were abolished in May 2024, every notarial act now lives digitally, permanently.Insurance OfficesLaw 4583/2018, customer-needs evidence, policy records, and stronger protection for health and claims data.Law OfficesLegal professional privilege (Law 4194/2013) becomes a technical requirement once GDPR Article 32 applies.