Who Holds the Record · country brief · data as of 2026-10-02Who holds the health record in Comoros?
In 2026, Comoros scores 32 of 100 on a person's right to see, control and share their own health record: rank 149= of 196 countries (likely range 112 to 170), in the Weak band (25 to 44). Who holds the keys: Institutional. Source: Who Holds the Record, SuperTruth, data as of 2026-10-02.
Comoros has had a data protection law since 2014, but no working regulator was found, and health records stay on paper or in separate systems.
Published · updated · data as of 2026-10-02 · research tool, not legal advice
Can I get my health records in Comoros?
Access to the full record scores 35 of 100 in Comoros, against a median of 43 across 196 countries. Article 219 of the 2011 Public Health Code gives patients the right to the information in their file. The 2014 data law adds a copy, but for a fee, through a doctor for medical data, with no deadline and no portal, so 35.
Can I control who sees my health record in Comoros?
Control and consent scores 28 of 100 in Comoros, against a median of 30 across 196 countries. The 2014 law requires express consent for health data, but it exempts treatment and health research, and there is no opt-out from sharing and no access log for patients. National health data were hosted in Rwanda before a local server room opened in 2023.
Eight rights, against Equatorial Guinea, Sao Tome and Principe, Central African Republic and the EU
| Patient access to the full record20% | 35 | 40 · 35 · 40 | |
|---|---|---|---|
| Patient control and consent20% | 28 | 28 · 28 · 28 | |
| Privacy and security15% | 45 | 45 · 45 · 45 | |
| Connected care journey15% | 25 | 18 · 22 · 20 | |
| Protection from commercial use10% | 40 | 40 · 43 · 42 | |
| Clinician access at the point of care10% | 15 | 15 · 17 · 15 | |
| Research and trial consent5% | 49 | 49 · 45 · 49 | |
| Clinical AI governance5% | 20 | 18 · 18 · 20 |
Black dot: Comoros. Hollow dots: Equatorial Guinea, Sao Tome and Principe, Central African Republic (scores on the right, same order). Grey line: median of all 196 countries. Dashed teal line: EU median. Overall: Comoros 32, EU median 61. Scores move in steps of about 5; read the rank with its likely range.
What would Comoros need to change to score higher?
Comoros sits in Weak (25 to 44); Mixed starts at 45. The two rights furthest below the 196-country median, weighted, are connected care journey (25, median 38) and clinician access at the point of care (15, median 34). The published rubric reads:
- Connected care journey: Primary care, hospitals, labs, pharmacy, claims and public health linked to one record and used at national scale.
- Clinician access at the point of care: Treating clinicians able to see the full record across providers, under consent and emergency rules.
Which laws give health record rights in Comoros?
- Loi N°14-029/AU portant protection des données à caractère personnel (2014): Health data needs express consent, with exceptions for treatment and research; creates a data commission; penalties up to 10 years.
- Loi N°11-001/AU portant Code de la Santé Publique (2011): Patient right to the information in their file, medical secrecy, device rules covering software, trial safeguards.
- Loi N°21-012/AU relative à la Cyber Sécurité et à la Lutte contre la Cybercriminalité (2021): Cybersecurity law with offences for misuse of personal data and an unsubscribe rule for marketing messages.
Strain and split context, not scored
- Doctors per 10,000
- 4.2 2022
- Nurses and midwives per 10,000
- 16.4 2022
- Private insurance + out-of-pocket
- 59.2% 2023
- Record reaches private care?
- unknown
Published stories
- none published in the last two years
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