Radiology Information System User Roles & Permissions

Radiology Information System User Roles & Permissions

The Radiology Information System (RIS) manages sensitive imaging workflows and must enforce strict role‑based and context‑based access controls aligned with UAE regulations (Federal Law No. 2/2019, UAE PDPL, DOH ADHICS, DHA/NABIDH, Malaffi). This document defines roles, permissions, hierarchies, and safeguards (including break‑the‑glass) for the RIS module.


Role Definitions

Shared entities (patients, providers, encounters, facilities, users) are owned by other modules; RIS references them via foreign keys as per project-wide rules.

Radiology Receptionist

  • Description
    Front-desk staff for radiology, handling patient arrival, identity verification, scheduling adjustments, and basic insurance/prior-auth checks for imaging exams.

  • Typical UAE Job Titles

  • Radiology Receptionist
  • Radiology Registration Clerk
  • Radiology Front Desk Officer

  • Scope of Access

  • Patients:
    • All patients scheduled for radiology exams at their assigned facility/department.
    • No access to detailed clinical content (images, reports) beyond minimal exam metadata.
  • Data Types:

    • View: demographics, identifiers (Emirates ID, MRN), appointments, radiology orders summary (exam type, priority, status), insurance coverage, prior-auth status.
    • Edit: check-in status, contact details (where allowed by facility policy), appointment times, basic order scheduling fields (scheduled slot, modality resource).
    • No access to report text, images, or dose details.
  • Reporting Hierarchy

  • Reports to: Radiology Supervisor / Radiology Department Administrator.
  • Collaborates with: Radiology Technologists, Insurance Coordinators, Scheduling team.

Radiology Technologist

  • Description
    Licensed imaging technologist performing image acquisition and basic QA, managing modality worklists, and capturing dose and contrast data.

  • Typical UAE Job Titles

  • Radiographer / Radiology Technologist
  • CT Technologist, MRI Technologist, Ultrasound Technologist
  • Senior Radiographer (non-lead)

  • Scope of Access

  • Patients:
    • Patients with active or scheduled exams on modalities assigned to the technologist’s department and shift.
  • Data Types:

    • View: full exam details, clinical indication, relevant prior imaging metadata, protocol details, radiation dose history summary.
    • Edit: exam status, technologist notes, contrast administration details, dose records (where not auto-populated), QA flags, modality selection.
    • No permission to edit radiologist reports or reading assignments.
  • Reporting Hierarchy

  • Reports to: Lead Technologist / Radiology Supervisor.
  • Clinical oversight: Chief Radiologist (for QA and protocol adherence).

Lead Technologist

  • Description
    Senior technologist overseeing modality operations, technologist scheduling, protocol adherence, and frontline QA.

  • Typical UAE Job Titles

  • Lead Radiographer
  • Modality Supervisor (e.g., CT Supervisor, MRI Supervisor)
  • Senior Radiology Technologist

  • Scope of Access

  • Patients:
    • All patients undergoing imaging in assigned modality group(s) and facility.
  • Data Types:

    • All Radiology Technologist permissions (“all_tech”).
    • Additional: manage modality worklists, assign/override protocols (within policy), manage technologist assignments, view QA metrics per technologist, manage modality resource availability (slots, downtime).
  • Reporting Hierarchy

  • Reports to: Radiology Department Manager / Chief Radiologist (operational).
  • Supervises: Radiology Technologists and Radiology Receptionists (in some facilities).

Radiologist

  • Description
    Licensed physician specialized in radiology, responsible for image interpretation, report creation, and critical result communication.

  • Typical UAE Job Titles

  • Consultant Radiologist
  • Specialist Radiologist
  • Radiology Fellow (with supervised reading rights)

  • Scope of Access

  • Patients:
    • Patients whose exams are on their reading worklist, assigned to their service, or within their on-call coverage.
    • Read-only access to prior imaging and relevant clinical context for those patients.
  • Data Types:

    • View: full imaging history, clinical indication, prior reports, dose history, lab summaries relevant to imaging.
    • Edit: report text (findings, impression), structured findings, critical flags, addenda, protocol selection for future exams, worklist claim/release.
    • Cannot modify administrative scheduling or billing data.
  • Reporting Hierarchy

  • Reports to: Chief Radiologist / Radiology Department Head.
  • May supervise: Fellows, Residents (if present), and junior radiologists.

Chief Radiologist

  • Description
    Departmental clinical leader responsible for radiology governance, QA, protocol and template management, and oversight of reporting quality.

  • Typical UAE Job Titles

  • Head of Radiology Department
  • Chief of Radiology
  • Radiology Medical Director

  • Scope of Access

  • Patients:
    • All radiology patients within the facility or multi-facility group (subject to facility policy).
  • Data Types:

    • All Radiologist permissions (“all_radiologist”).
    • Additional: manage report templates, approve report corrections, override protocols, manage reading assignments, view department-wide QA and analytics dashboards, access anonymized datasets for QA and teaching.
  • Reporting Hierarchy

  • Reports to: Chief Medical Officer / Medical Director.
  • Supervises: Radiologists, Lead Technologists, Radiation Safety Officer (for imaging-related clinical matters).

Radiation Safety Officer (RSO)

  • Description
    Specialist responsible for radiation protection, dose monitoring, and compliance with UAE MOH and DOH/DHA radiation safety standards.

  • Typical UAE Job Titles

  • Radiation Safety Officer
  • Medical Physicist (with RSO designation)
  • Radiation Protection Officer

  • Scope of Access

  • Patients:
    • All patients with radiation-emitting exams (CT, fluoroscopy, nuclear medicine, interventional radiology) across assigned facilities.
  • Data Types:

    • View: detailed dose records, cumulative dose history, modality-level dose metrics, DRL benchmarks, alerts.
    • Edit: dose thresholds, DRL benchmark tables, RSO notes, regulatory reporting configurations.
    • No permission to edit clinical report text or scheduling.
  • Reporting Hierarchy

  • Reports to: Chief Radiologist and/or Quality & Patient Safety Director.
  • Collaborates with: Radiologists, Lead Technologists, Facility Safety Officer.

Radiology Nurse

  • Description
    Nurse supporting imaging procedures, including contrast administration, sedation, safety screening, and monitoring.

  • Typical UAE Job Titles

  • Radiology Nurse
  • Interventional Radiology Nurse
  • MRI/CT Nurse

  • Scope of Access

  • Patients:
    • Patients scheduled or undergoing imaging in assigned radiology units during their shift.
  • Data Types:

    • View: exam details, clinical indication, allergies, medications, vital signs, relevant labs (e.g., creatinine), consent status.
    • Edit: safety screening forms, contrast administration records, sedation records, adverse reaction documentation, nursing notes related to imaging.
    • No permission to edit radiologist reports or dose thresholds.
  • Reporting Hierarchy

  • Reports to: Radiology Nursing Manager / Radiology Department Manager.
  • Clinical oversight: Chief Nursing Officer and Chief Radiologist (for imaging-specific protocols).

Ordering Physician (External Role)

  • Description
    Non-radiology provider who orders imaging exams and needs visibility into order status and results.

  • Typical UAE Job Titles

  • Consultant / Specialist (Internal Medicine, Surgery, Emergency, etc.)
  • General Practitioner
  • External Referring Physician (network clinics)

  • Scope of Access

  • Patients:
    • Patients for whom they are the ordering or attending physician, or for whom they have documented coverage.
  • Data Types:

    • View: order status, scheduled time, report status, final and preliminary reports, critical result notifications for their patients.
    • Edit: acknowledge critical results, request clarification, request addendum (via messaging), cancel or modify their own orders (subject to policy).
    • No access to modality configuration, dose thresholds, or other patients’ imaging data.
  • Reporting Hierarchy

  • Reports to: Their own clinical department leadership (outside RIS).
  • RIS interaction is via EHR/physician portal; RIS enforces role-based access for imaging data.

Permission Matrix

Legend:

  • ✅ = Allowed
  • ❌ = Not allowed
  • 🔒 = Conditional (context-based, co-sign, or configuration-dependent)
Permission / Function Radiology Receptionist Radiology Technologist Lead Technologist Radiologist Chief Radiologist Radiation Safety Officer Radiology Nurse Ordering Physician
Patient & Order Access
View patient demographics (RIS context) ✅ (own patients)
Edit contact details (phone, email) 🔒¹ 🔒¹ 🔒¹
View radiology order details (exam, priority, indication summary) ✅ (indication masked if policy) ✅ (own orders)
Create new radiology order 🔒² 🔒² ✅ (via CPOE)
Modify radiology order (before scheduling) 🔒³ 🔒³ 🔒³ ✅ (own orders)
Cancel radiology order 🔒³ 🔒³ 🔒³ ✅ (own orders)
View full clinical indication text 🔒⁴ 🔒⁴ ✅ (own patients)
Scheduling & Worklists
View radiology schedule (all modalities) ✅ (assigned modalities) 🔒⁵ 🔒⁵ ✅ (assigned areas) ✅ (own patients only)
Manage patient check-in (arrived / no-show)
Assign exam slot / reschedule exam 🔒⁶ 🔒⁶ 🔒⁶ (request only)
Manage modality worklist (DICOM MWL push)
Manage radiologist reading worklist (assign/redistribute) 🔒⁷ ✅ (claim/release own)
Exam Execution & Dose
Update exam status (Arrived / In Progress / Completed / No-show)
Record technologist notes ✅ (nursing notes)
Record contrast administration details 🔒⁸
Manage sedation records
Record radiation dose manually
View detailed radiation dose record (per exam) 🔒⁹ 🔒⁹
Configure dose thresholds / DRLs 🔒¹⁰
View radiation dose dashboard (aggregated) 🔒¹¹ 🔒¹¹ 🔒¹¹ 🔒¹¹
Reporting & Interpretation
View images via PACS link ✅ (for own exams) 🔒¹² ✅ (for own patients) ✅ (own patients)
Dictate / edit report findings & impression
Use structured reporting templates
Sign preliminary report
Sign final report 🔒¹³
Create report addendum 🔒¹⁴ (request only)
Approve report corrections / major amendments
Manage report templates (create/edit/deactivate) 🔒¹⁵
Critical Results & Notifications
Flag finding as critical
Initiate critical result notification workflow
View critical result notifications (for own patients) 🔒¹⁶
Acknowledge critical result 🔒¹⁷ 🔒¹⁷ ✅ (if recipient) ✅ (if recipient)
Document read-back confirmation
View critical result compliance dashboard 🔒¹¹ 🔒¹¹
Admin & Configuration
Manage modality resources (add/edit AE title, slots, maintenance) 🔒¹⁸
Manage imaging protocols ✅ (protocol_exams) ✅ (override_protocols) 🔒¹⁸
Manage reading assignments 🔒¹⁹ 🔒¹⁹
Manage radiology templates 🔒¹⁵
View radiology analytics dashboard (TAT, productivity, etc.) 🔒²⁰ 🔒²⁰ 🔒²⁰ 🔒²⁰
Security & Oversight
View exam/report audit log 🔒²¹ 🔒²¹ 🔒²¹ 🔒²¹ (own patients)
Break-the-glass access to restricted imaging data 🔒²² 🔒²² 🔒²² 🔒²² 🔒²² 🔒²² 🔒²²
Export de-identified imaging metrics (for QA/research) 🔒²³

Footnotes (conditional rules)
1. Edit contact details: Allowed only if facility policy delegates demographic updates to radiology; otherwise read-only.
2. Radiologist order creation: Typically via CPOE; direct order entry in RIS may be enabled for internal add-on views (e.g., additional sequences) with governance.
3. Modify/cancel order: Only before exam start; may require confirmation from ordering physician or department policy.
4. Clinical indication visibility: Receptionist and RSO may see abbreviated or masked indication depending on privacy policy (e.g., for sensitive diagnoses).
5. Radiologist schedule view: Limited to reading worklist and high-level schedule; no access to non-assigned patient details.
6. Rescheduling: Nurse/Technologist may propose or perform rescheduling within defined rules (same day, same modality) as configured.
7. Reading worklist management: Lead Technologist may reassign exams between radiologists only if delegated by Chief Radiologist.
8. Contrast administration: Receptionist may record pre-exam oral contrast instructions only; IV contrast administration is Nurse/Technologist.
9. Dose visibility: Ordering Physician and Nurse may see summary dose (e.g., “within DRL / above DRL”) rather than full technical details, depending on configuration.
10. Dose thresholds: Typically RSO; Chief Radiologist may co-approve changes.
11. Aggregated dashboards: Technologists/Lead Technologists may have read-only access to metrics relevant to their performance.
12. RSO image access: For QA and dose investigations; may be restricted to anonymized views where feasible.
13. Final report signing: Some facilities restrict final signing to consultants; specialists/fellows may sign preliminary only.
14. Addendum requests: Ordering Physician can request; only Radiologist/Chief Radiologist can create/sign.
15. Template management: Radiologists may propose templates; Chief Radiologist approves and publishes.
16. RSO critical notifications: RSO may view where related to radiation safety incidents.
17. Critical acknowledgement: Usually Ordering Physician or covering provider; Radiologist may acknowledge when they are the recipient (e.g., interdepartmental).
18. RSO protocol involvement: RSO may comment on protocols from radiation safety perspective; not primary owner.
19. Reading assignments: Lead Technologist may manage operational assignment (e.g., overnight coverage) under Chief Radiologist’s rules.
20. Analytics dashboard: Limited views for non-lead roles (e.g., own productivity).
21. Audit log: Broader access for QA and compliance roles; restricted for frontline staff.
22. Break-the-glass: Only for genuine emergency; see BTG section below.
23. De-identified exports: Must comply with Federal Law No. 2/2019 and PDPL; typically restricted to Chief Radiologist/RSO with ethics/QA approval.


Role Hierarchy

flowchart TD CMO["Chief Medical Officer / Medical Director"] --> CR["Chief Radiologist"] CR --> Rad["Radiologist"] CR --> LT["Lead Technologist"] CR --> RSO["Radiation Safety Officer"] CR --> RNM["Radiology Nursing Manager"] RNM --> RN["Radiology Nurse"] LT --> RT["Radiology Technologist"] LT --> RR["Radiology Receptionist"] OPH["Ordering Physician (External)"]:::external classDef external fill:#fff,stroke:#999,stroke-dasharray: 5 5;

Inheritance Principles

  • Chief Radiologist inherits all Radiologist permissions plus: template management, protocol override, reading assignment management, and full analytics access.
  • Lead Technologist inherits all Radiology Technologist permissions plus: modality resource management, technologist scheduling, and QA oversight.
  • Radiology Nursing Manager (not explicitly modeled as a separate RIS role here) would inherit Radiology Nurse permissions plus staff oversight and limited dashboards.
  • Ordering Physician is an external role: primary permissions are defined in CPOE/EHR modules; RIS grants read/acknowledge capabilities for imaging data for their patients.

Context-Based Access Rules

RIS must implement RBAC + CBAC (role-based plus context-based access control) aligned with UAE regulations and ADHICS/NABIDH/Malaffi requirements.

1. Facility-Based Restrictions (Multi-Facility)

  • Users are associated with one or more facilities.facility_id.
  • Default rule:
  • Radiology Receptionist, Technologist, Lead Technologist, Radiology Nurse: access limited to exams and orders where facility_id is in their assigned facility list.
  • Radiologist and RSO: may have multi-facility access if contracted across sites; otherwise restricted similarly.
  • Multi-emirate groups (e.g., Dubai + Abu Dhabi):
  • Access must respect emirate-specific HIE policies (NABIDH vs Malaffi).
  • Cross-facility access for clinicians must be justified by treating relationship or on-call coverage.

2. Department-Based Restrictions

  • Access is further constrained by departments.department_id:
  • Technologists and Nurses see exams only for radiology and sub-departments (CT, MRI, IR, etc.) they are assigned to.
  • Interventional Radiology may have additional restrictions due to procedural nature (e.g., limited to IR team).
  • RSO may access dose data across all departments using radiation-emitting equipment (including Cath Lab, OR C-arms) if configured.

3. Patient Relationship Requirements

  • Radiologist:
  • Full report and image access only for exams on their reading worklist, assigned to them, or within their on-call coverage.
  • Prior imaging for the same patient is accessible when they are actively interpreting a current exam for that patient.
  • Ordering Physician:
  • Access limited to imaging data for patients where they are the ordering or attending provider, or documented covering provider.
  • Historical imaging outside their treatment episodes may require BTG or explicit consent (e.g., for medico-legal review).
  • Radiology Nurse / Technologist:
  • Access limited to patients with active or scheduled exams during their shift and in their assigned modalities.

4. Time-Based Access (Shift-Based)

  • Each user has assigned shifts or on-call periods:
  • Technologists and Nurses: write access (status updates, notes, contrast records) only during active shifts; outside shift, access becomes read-only or fully blocked.
  • Radiologists: reading worklist access is continuous, but on-call overrides (e.g., ED imaging) are only active during on-call windows.
  • RSO: configuration access (thresholds, DRLs) limited to business hours or defined maintenance windows.
  • Night-shift rules:
  • Critical result notifications during night shifts must still be acknowledged within defined SLAs; system escalates per workflow WF-RIS-005.
  • High-risk configuration changes (protocols, DRLs) may be blocked outside business hours unless dual-approval is obtained.

5. Emergency / On-Call Overrides

  • Emergency Department / Trauma:
  • Radiologists on ED/trauma call may access imaging for any ED patient during their on-call period, even if not pre-assigned to their worklist.
  • Technologists on trauma call may see all ED/trauma imaging orders for rapid triage.
  • Code Stroke / Code Trauma:
  • System may temporarily relax some worklist restrictions (e.g., auto-assign to on-call neuroradiologist) while maintaining full audit logging.
  • On-Call Cross-Facility:
  • On-call radiologists covering multiple facilities may be granted temporary cross-facility access during the on-call window, automatically revoked at end of shift.

Break-the-Glass (BTG) Procedures

BTG is required to access imaging data outside normal RBAC/CBAC rules, especially for restricted clinical data (e.g., mental health-related imaging, forensic cases, VIP patients) as mandated by Federal Law No. 2/2019 and UAE PDPL.

1. When BTG is Required

  • Accessing imaging exams or reports for a patient:
  • With a VIP / restricted flag (e.g., government officials, staff, high-profile individuals).
  • Outside the user’s assigned facility/department or treating relationship, where no active assignment exists.
  • With sealed envelope classification (e.g., sensitive mental health, sexual assault, legal/forensic imaging).
  • Accessing historical imaging for medico-legal review when the user is not part of the current care team and no explicit authorization is recorded.

2. BTG Workflow

  1. Trigger
    - User attempts to open a restricted exam/report or patient imaging history and is blocked by standard access rules.

  2. Warning & Justification
    - System displays a prominent warning:
    “You are requesting emergency access to restricted imaging data. This action will be fully audited and reviewed. Proceed only if necessary for immediate patient care or safety.”
    - User must select a reason from a controlled list (e.g., “Emergency treatment”, “On-call coverage”, “Public health emergency”, “Regulatory/legal requirement”) and optionally enter free-text justification.

  3. Authentication Step-Up
    - System may require re-authentication or MFA (per ADHICS/NESA guidance) before granting BTG access.

  4. Access Scope & Duration
    - Access is limited to:

    • The specific patient and exam(s) requested.
    • A short time window (e.g., 30–60 minutes).
    • No configuration or admin privileges are granted via BTG.
  5. Audit Trail
    For each BTG event, system logs at minimum: - User ID, role, department, facility.
    - Patient ID, exam ID(s), report ID(s).
    - Timestamp (start and end of BTG session).
    - Reason code and free-text justification.
    - Source IP / device ID.
    - Actions performed (viewed images, viewed report, printed, exported, etc.).

  6. Notifications
    - Automated notification to:

    • Data Protection Officer / Compliance team.
    • Chief Radiologist (for radiology-related BTG).
    • For VIP patients, optional alert to designated privacy officer.

3. Post-Access Review

  • Daily/Weekly Review
  • Compliance or Privacy Officer reviews all BTG events within a defined timeframe (e.g., 24–72 hours).
  • Events are classified as Justified, Questionable, or Unjustified.
  • Follow-Up Actions
  • Justified: documented in patient record if clinically relevant.
  • Questionable: clarification requested from user; additional training may be mandated.
  • Unjustified: escalated to HR/medical leadership; may result in disciplinary action or access revocation.
  • Retention
  • BTG audit logs retained at least as long as clinical records, and in line with PDPL and Federal Law No. 2/2019 requirements (often 15+ years for clinical data).

4. UAE PDPL Implications

  • BTG processing is justified under treatment or vital interests exemptions; explicit consent is not required in emergencies but must be documented.
  • System must ensure BTG is exceptional, not a routine way to bypass RBAC.
  • BTG logs support PDPL requirements for accountability, transparency, and breach investigation.

Segregation of Duties

To reduce fraud, error, and privacy risks, certain role combinations and actions must be segregated.

1. Conflicting Role Combinations

The following combinations should not be assigned to the same user account:

Role A Role B Risk Policy
Radiology Receptionist Chief Radiologist Excessive access from front desk to full clinical/admin control Prohibited
Radiology Receptionist RSO Mix of front-desk and safety oversight; privacy risk Strongly discouraged
Radiology Technologist Ordering Physician Self-ordering and self-execution of exams Prohibited except in very small facilities with compensating controls
Radiology Technologist Radiologist Ability to both acquire images and sign reports under same identity Prohibited; if a physician occasionally performs technologist tasks, separate accounts/roles must be used
Lead Technologist Chief Radiologist Concentration of operational and clinical authority Allowed only with explicit approval and enhanced audit if small facility
RSO Radiology Receptionist Safety oversight plus front-desk demographic access Prohibited
RSO Chief Radiologist May be allowed but requires clear governance to avoid unchecked changes to DRLs and protocols Requires documented approval

2. Dual Sign-Off Requirements

Certain high-risk actions require dual approval:

  • Protocol Changes for High-Dose Exams (e.g., CT perfusion, interventional procedures):
  • Proposed by: Lead Technologist or Radiologist.
  • Approved by: Chief Radiologist and RSO.

  • DRL Threshold Changes:

  • Configured by: RSO.
  • Approved by: Chief Radiologist (clinical) and Quality/Safety Committee (governance).

  • Major Report Corrections / Amendments (e.g., change in diagnosis with clinical impact):

  • Addendum created by: Radiologist.
  • Correction approval: Chief Radiologist (or designated senior radiologist) before redistribution.

  • De-identified Data Export for Research:

  • Requested by: Chief Radiologist or RSO.
  • Approved by: Ethics/Research Committee and Data Protection Officer.

  • Critical Result Workflow Configuration (escalation timings, channels):

  • Configured by: Radiology IT Admin / Lead Technologist.
  • Approved by: Chief Radiologist and Quality & Patient Safety.

All dual sign-off actions must be fully audited with both approvers’ identities and timestamps.


UAE Regulatory Compliance

RIS access control and permissions must support compliance with:

1. Federal Law No. 2 of 2019 (Use of ICT in Health Fields)

  • Ensures confidentiality and integrity of health data, including imaging.
  • Requires that access be limited to authorized personnel and that all accesses be logged.
  • RIS must support:
  • Role-based and context-based access to imaging data.
  • Comprehensive audit logs for all view/edit actions on radiology orders, exams, reports, and dose records.
  • Data residency in UAE for all radiology data and logs.

2. UAE PDPL (Federal Decree-Law No. 45/2021)

  • Imaging data is sensitive personal data (health data).
  • RIS must:
  • Enforce least-privilege access based on role and context.
  • Support BTG with full audit and review.
  • Enable data subject rights via integration with EHR/portal (access to reports, correction workflows).
  • Tag processing purposes (treatment, QA, research) for analytics and exports.

3. DOH (Abu Dhabi) – ADHICS & Malaffi

  • ADHICS requires strong access control, MFA for remote access, and detailed audit logging.
  • Malaffi integration (INT-RIS-005) requires that only appropriate, finalized reports be shared; RIS permissions must ensure only authorized radiologists can finalize and release reports.
  • Dose monitoring and DRL compliance support DOH radiation safety expectations.
  • NABIDH mandates standardized imaging data sharing (INT-RIS-004) with appropriate consent and access controls.
  • eClaimLink prior authorization workflows (INT-RIS-008) require that only authorized staff (Receptionist/Insurance Coordinator) manage prior-auth data; radiologists should not alter financial/authorization data.
  • RIS must support role-based separation between clinical and financial workflows.

5. TDRA / NESA / ADHICS Cybersecurity

  • Access control and BTG must align with national cybersecurity frameworks:
  • Strong authentication, especially for remote access to imaging and reports.
  • Principle of least privilege and segregation of duties.
  • Regular review of access rights and audit logs.

This roles & permissions specification should be used by the development team to implement RIS RBAC/CBAC, BTG workflows, and audit logging, and by governance teams to configure facility-specific policies within the UAE regulatory context.

content/clinical/ris/02-roles-permissions.md Generated 2026-02-20 22:54