The Malta Sociological Association (MSA) notes the public consultation on the Digital Health and Health Data Strategy 2030. The MSA welcomes the emphasis placed on patient-centred care, digital transformation, and innovation, including the use of artificial intelligence and health data. At the same time, the MSA strongly recommends the systematic incorporation of Social Impact Assessment (SIA) within the design, implementation, and monitoring of this strategy, in order to assess how digital health reforms interact with social life, social inequalities, and existing patterns of access to healthcare.
The International Association for Impact Assessment defines Social Impact Assessment as “the processes of analysing, monitoring and managing the intended and unintended social consequences, both positive and negative, of planned interventions (policies, programs, plans, projects) and any social change processes invoked by those interventions”. An SIA is an interdisciplinary process, and should employ various methods, both quantitative and qualitative. Social impact assessments should not be one-off exercises, but ongoing processes which engage with various stakeholders and which report back so as to ensure effective policy processes.
From this perspective, digital health and health data initiatives are not purely technical or administrative interventions, but social processes that may have differentiated impacts across population groups. These include, among others, issues related to digital health literacy, unequal access to digital tools, trust in data governance, data privacy, the reshaping of patient–provider relationships, and the implications of algorithmic decision-making for equity and accountability within healthcare systems. An SIA would ensure that public expectations are met, local norms are respected, and that exposure to risk (especially for the secondary use of health data) at different levels within society is mitigated. It also ensures transparency about AI training, including opportunities and limitations, and the inclusivity of minority groups in the building of health digital platforms to ensure accessibility.
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