Judging from communications and reactions from physicians and the Serbian Medical Chamber Commissioner for Information of Public Importance and Personal Data Protection Rodoljub Sabic considers that there are numerous dilemmas in connection with the future duty of doctor's offices, clinics, hospitals etc. to issue fiscal charge slips to patients for services provided as of 1 June 2009.
The Commissioner thinks that the Ministry of Health must make additional effort with other competent ministries in order to eliminate dilemmas if possible and prevent possible risks of processing of patients' privacy.
In connection with this, the Commissioner also said the following:
"It is very important to eliminate all doubts in connection with possible threats to privacy, i.e. violation of personal data protection. Information on health status is classified as particularly sensitive information under Article 16 of the Law in Personal Data Protection. That means that processing of such information (recording, use, allowing access or making otherwise available) is allowed only with a consent from a person it relate to and only exceptionally without a consent in cases when it is expressly stipulated under the Law and for the purposes set under the Law.
However, certain powers of inspection authorities which relate to control of fiscal charge slips in general might in practice lead to processing of information on health status of patients, which would, directly or indirectly, have to be covered by fiscal charge slips, without a requisite, explicit legal basis.
From the aspect of real fiscal interests, this fiscalization is an abstract measure which should not be rushed into because it does not have any actual effects in terms of additional budget revenue. Namely, although medical institutions will have the duty to issue fiscal charge slips, they are still exempted from the VAT. This means that there is enough time to take necessary measures in order to review all open issues and dilemmas present in the public and the expert community and to eliminate them if possible."