larger amounts of data of one single pseudonym then
de-pseudonymization may be possible. Since insured
persons get a new pseudonym with every EHC (i.e.
at least every five years) in most cases this should
be no real danger. More significantly, card issuers
could perform a de-pseudonymization. This can only
be done by a few selected people and only if the
data protection official of the card issuer is involved
(gematik, 2008a, p.170f).
If data is exchanged with a health insurance then care
providers always have to be anonymized (gematik,
2008b, p.31). In addition the institution of a care
provider has to be anonymized when querying
insured person’s master data (gematik, 2009b, p.38).
This way one seeks to prevent the possibility of
creating profiles of insured persons.
2.1.2 Data Access, Preservation and
Transferability
Access on EHC, HPC or SMC-B is only allowed us-
ing the connector. However, the connector will not be
available from start, so it may be set aside (gematik,
2009b, p.39), meaning that card readers can be di-
rectly connected to the clients of care providers. Once
connectors are available the protected parts of insured
persons’ master data can then be saved to the pro-
tected area of the EHC. Until then they may temporar-
ily be saved to the freely readable part of the EHC (for
a time period not yet defined) (gematik, 2009a, p.15),
as is the current state of health insurance cards (HIC).
Insured persons have the possibility to access their
own data with write access to emergency records and
read access to the rest. Since prescriptions are rela-
tively often filled by proxy persons the delegation of
these rights to other insured persons will be possible
(gematik, 2009b, p.92).
Every access to an EHC or into the HTI will be au-
dited. Access will not be granted if auditing fails.
Replacing an EHC does not mean loss of data, since
existing data stored in the HTI can be transcoded.
2.2 Public Key Infrastructures
A public key infrastructure (PKI) is a trustworthy unit
helping to check certificate validity and issuing new
certificates. That way requests can only be conducted
by registered components and can be verified, pre-
venting man in the middle attacks and replay attacks.
Mutual checks happen on all levels in the HTI. The
smart cards that are used can perform such a check
with a few restrictions even without availability of the
HTI by using Card Verifiable Certificates (CVCs).
Certificates that are necessary for authentication must
contain the role of certificate owners (gematik, 2009b,
p.309). Otherwise a role assignment register would be
needed. The PKIs in the HTI provide the possibility to
verify X.509 certificates and CVCs (gematik, 2009b,
p.49). The PKI in the HTI is divided in two parts: one
for infrastructure, and one for persons and institutions
(gematik, 2009b, p.141). It will not be possible to use
services in the HTI by fraud with a fake certificate.
Additionally a security alarm would be executed by a
failed authentication (gematik, 2008b, p.127), allow-
ing counter measures.
Requesting certificate state is done by using the On-
line Certificate Status Protocol (OCSP).In exceptional
cases certificate revocation lists (CRLs) are allowed
(gematik, 2009b, p.142). OCSP does not use black-
listing. It returns the state in the CA data base, making
a revocation immediately active. OCSP answers may
be cached, but there is no severe threat that a revoked
certificate will be seen as valid by mistake, since they
are rarely used in such short intervals (the cache nor-
mally lasts 12 to 24 hours) (gematik, 2009b, p.303f).
It has to be considered as critical that non-availability
of a revocation list of integrity must not lead to the
result of all objects being considered as revoked as a
precaution (gematik, 2008b, p.78). If the PKI is avail-
able, but no data of revoked objects can be accessed
then all certificates had to be accepted if there were
no contradictory data cached. Availability would oth-
erwise not be given, but at least a security alert should
be executed.
CVCs allow smart cards to independently verify cer-
tificates. They are used for mutual authentication
of EHCs, HPCs and SMC-As/-Bs (gematik, 2008b,
p.68). Since the public certificate of the issuing CA is
known (gematik, 2008b, p.82), validity verification is
directly possible. However it is not possible to verify
if a CVC has been revoked. Corresponding X.509 cer-
tificates are verified when using services in the HTI.
A revoked card may therefore not be misused if at-
tackers can not also disrupt the availability of the HTI
at the same time.
2.3 Data Transfer and Data Storage
Connection between card reader and connector is
encrypted and mutual authentication is required
(gematik, 2008b, p.51). Since part of the connec-
tion to professional services lie in the internet it is
open for attacks. Therefore connectors have to be
approved (gematik, 2008a, p.238) and they possess
an integrated VPN client, allowing a connection us-
ing IPSec and mutual authentication (gematik, 2008b,
p.121). At the other end of the connection a firewall
should be passed before reaching a VPN concentra-
tor, which may also include a packet filter (gematik,
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