CHANCELLOR OF JUSTICE AS THE PREVENTIVE MECHANISM The PBGB in reply to the Chancellor’s enquiry admitted that no substantial progress with the issue of provision of health services to asylum seekers had occurred by the beginning of 2011. After the creation of the PBGB on 1 January 2010, the priority was to harmonise and regulate in a uniform manner asylum procedures in the PBGB. Internal guidelines of the PBGB do not establish the duty of performing the initial health examination of asylum seekers. By the beginning of 2011, initial health examination of asylum seekers had never been performed because no need for this had occurred. There had also been no need to provide emergency or other medical care to asylum seekers. The PBGB noted that in case of a need health examination of asylum applicants is performed. The following part contains an overview of additional recommendations made by the Chancellor as a result of the inspection visits. 2. Inspection visit to Illuka Reception Centre for Asylum Seekers In addition to the above general issues in connection with the provision of health services to asylum seekers, the issue of guaranteeing confidentiality of health data concerning access to a doctor, handing over letters of referral to the staff of the reception centre and drawing up expense documents for the provision of health services arose during the inspection visit. The Chancellor made the following recommendations to the reception centre: 1) ensure compliance with the principle of purposefulness and minimalism in the processing of personal data of asylum seekers and, on this basis, as a rule not oblige asylum seekers to disclose the substance of their health data as a precondition for a doctor’s appointment more than is necessary for arranging the assistance; 2) ensure submitting of expense documents concerning health services to the Ministry of Social Affairs, which handles the accounts, so that documents do not reveal personalised health data. The reception centre noted in its reply that expense documents concerning health services are sent by the institutions providing the service and the institution cannot guarantee that the expense documents do not reveal any personalised health data if such data have been entered in the documents. Second, the issue of whether the principle of personal data protection is guaranteed when organising the purchasing of medicines and whether the activity of the reception centre in refusing to purchase certain medicines is in conformity with the law arose during the inspection visit. The Chancellor made the following recommendations to the reception centre: 1) ensure purchasing of medicines prescribed to asylum seekers by a doctor; 2) arrange purchasing of medicines in a manner that asylum seekers can maintain the confidentiality of their health data if they wish; 3) submit expense documents concerning purchasing of medicines in a manner which does not allow identifying a specific medicine and which complies with the principles of confidentiality of personal data; 4) provide a sufficient quantity of medical aids to asylum seekers for administering the prescribed medicines (e.g. disposable syringes and pen needles for the so-called syringe pens). The reception centre replied that the centre had guaranteed purchasing of medicines prescribed by the doctor and aids for administering the medicines. Purchasing of medicines is organised so that persons who have a prescription from a doctor give the prescription to the head of the centre who brings the necessary medicines from the pharmacy. Third, compliance with the principles of processing personal data in organising video surveillance in the reception centre was verified. The Chancellor recommended to the reception centre to notify asylum seekers in a language understood by them about the use of video surveillance and post the name and contact data of the processor of the data visibly in the reception centre. 44 The reception centre replied that the existence of video surveillance is notified through a note posted on the doors and the information board.