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  <front>
    <journal-meta />
    <article-meta>
      <title-group>
        <article-title>Health data leaks to third parties in web-based health services</article-title>
      </title-group>
      <contrib-group>
        <contrib contrib-type="author">
          <string-name>Sampsa Rauti</string-name>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Robin Carlsson</string-name>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Samuli Laato</string-name>
          <email>samuli.laato@tuni.fi</email>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Timi Heino</string-name>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Panu Puhtila</string-name>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Ville Leppänen</string-name>
          <email>ville.leppanen@utu.fi</email>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <aff id="aff0">
          <label>0</label>
          <institution>Tampere University</institution>
          ,
          <addr-line>Kalevantie 4, 33100 Tampere</addr-line>
          ,
          <country country="FI">Finland</country>
        </aff>
        <aff id="aff1">
          <label>1</label>
          <institution>University of Turku</institution>
          ,
          <addr-line>Vesilinnantie 5, 20500 Turku</addr-line>
          ,
          <country country="FI">Finland</country>
        </aff>
      </contrib-group>
      <abstract>
        <p>Today, users may share sensitive health data on web-based health services. We rely on these services to keep our data safe and secured, but this is not always the case. Therefore, this study investigates the privacy of a snapshot of 10 Finnish web-based health services, providing an analysis of health data leaks. We show that all analyzed services leaked at least some kind of personal data to third parties - from topics of visited pages to details on appointment bookings. While the situation has improved after we have notified the health service providers about this issue, the study serves as a reminder of the ongoing challenges in protecting user privacy in online health services and highlights the pressing need to address these issues.</p>
      </abstract>
      <kwd-group>
        <kwd>eol&gt;Medical websites</kwd>
        <kwd>data leaks</kwd>
        <kwd>data concerning health</kwd>
        <kwd>web privacy</kwd>
        <kwd>third-party services</kwd>
      </kwd-group>
    </article-meta>
  </front>
  <body>
    <sec id="sec-1">
      <title>1. Introduction</title>
      <p>
        Web-based health services have become a vital part of
essential electronic services [
        <xref ref-type="bibr" rid="ref1">1</xref>
        ]. Booking appointments, viewing
personal health information and test results, and searching
for health-related information can be conveniently carried
out online. Many web-based healthcare services, such as
medical centers’ websites, process sensitive personal
information concerning health. Due to the sensitivity of this
data, it is critical to ensure it remains confidential and does
not leak to third parties [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ].
      </p>
      <p>
        However, previous research has demonstrated that across
websites and services, regardless of sensitivity requirements,
numerous third-party services and components, such as web
analytics, are often used [
        <xref ref-type="bibr" rid="ref3 ref4">3, 4</xref>
        ]. Using such services makes
monitoring business goals and improving user experience
more convenient, but at the same time, there is a risk that
sensitive information is leaked through these third party
services. This typically happens without users’ knowledge, and
also unbeknownst to website developers and maintainers.
      </p>
      <p>This study conducts an in-depth examination of the
privacy of 10 web-based health services. We present an
overview of health data leaks, an issue that an even larger
group of web-based health services is likely to have. Our
study specifically focuses on the privacy and confidentiality
of Finnish web-based health services. Hence, in this study
we address the following research question: Do web-based
healthcare services leak sensitive data related to an individual
user’s health status? This paper serves as an analysis and
discussion on the privacy threats associated with integrating
third-party services in web-based health services.</p>
      <p>The rest of the paper is organized as follows. Section 2
reviews related work on the privacy of medical websites.
Section 3 outlines the study setting and the method,
describing how the studied websites were selected and how the
network trafic analysis was performed. Section 4 discusses
the results of our network trafic analysis and explores the
found data leaks. Section 5 presents a discussion on our
key findings and their implications. Section 6 concludes the
paper.</p>
    </sec>
    <sec id="sec-2">
      <title>2. Related work</title>
      <p>
        In recent years, a number of papers pertinent to our
research have been published. Huo et al. [
        <xref ref-type="bibr" rid="ref5">5</xref>
        ] analyzed 459
health-related web portals and found that Google
Analytics was used in 14% of them. Sensitive health data leaks
were present on 9 websites, and details on e.g. prescribed
medicines and laboratory results were transferred to third
parties. Libert [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ] investigates the problem of leaking health
data contained in URL addresses to third parties. Zheutlin
et al. [
        <xref ref-type="bibr" rid="ref7">7</xref>
        ] studied user data tracking through third-party
cookies on USA-based government, non-profit, and
commercial health-related websites, but did not go into detail
about what personal data is sent to third parties.
      </p>
      <p>
        Friedman et al. [
        <xref ref-type="bibr" rid="ref8">8</xref>
        ] discussed the risks of third-party
tracking technologies in hospital websites, highlighting
potential legal liabilities. Yu et al. [
        <xref ref-type="bibr" rid="ref9">9</xref>
        ] conducted a large-scale
automated survey on hospital websites around the world,
revealing that 53.5% of them employed tracking tools that
collected user data. Friedman et al. [
        <xref ref-type="bibr" rid="ref10">10</xref>
        ] examined the
prevalence of third-party tracking tools in abortion clinic websites
and concluded that the majority (99.1%) used some form
of tracking tool leaking user data to third parties. Surani
et al. [
        <xref ref-type="bibr" rid="ref11">11</xref>
        ] found clear deficiencies in privacy policies of
web-based health services.
      </p>
      <p>
        Huesch [
        <xref ref-type="bibr" rid="ref12">12</xref>
        ] reminds that searching and accessing free
health-related information online raises concerns about
privacy and the potential for information on a user’s health to
be used for profiling and targeted advertising. Wesselkamp
et al. [
        <xref ref-type="bibr" rid="ref13">13</xref>
        ] studied 385 medical websites in the EU area. They
found that 62% used tracking tools before user consent for
data collection and 15% tracked the user even after consent
rejection. Kes et al. [
        <xref ref-type="bibr" rid="ref14">14</xref>
        ] argue that collecting of users’ health
data on websites, despite privacy concerns, can lead to an
improved user experience akin to a personalized customer
relationship. Still, the actual benefits are debatable, and
transferring health data to third parties to improve targeted
advertising is very problematic in the light of the GDPR.
      </p>
      <p>
        Compared to many earlier studies, the current study
conducts a more in-depth examination of types of personal
data that web-based health services leak to third parties in
diferent scenarios. We show that the issue of third-party
analytics being present in web-based health services
remains a significant problem despite having been addressed
in research well over ten years ago [
        <xref ref-type="bibr" rid="ref15">15</xref>
        ].
      </p>
    </sec>
    <sec id="sec-3">
      <title>3. Study Setting and Method</title>
      <p>We selected 10 Finnish web-based health services for closer
inspection in this study. We chose the websites of several
important healthcare providers in Finland, such as
medical centers, therapy houses, and laboratories. We searched
healthcare providers using the Google search engine, with
keywords "lääkärikeskus" (medical center), "terapia"
(therapy) and "laboratorio" (laboratory). Instead of analyzing a
large number of health services, our study examines the
network trafic of these services more thoroughly. It includes
various usage scenarios where sensitive health data web
services process can leak to third parties. We examined the
data leaks in the chosen services two times, first in
December 2022 and then again in February 2024 after the service
providers had been informed of the issue.</p>
      <p>It is important to note that we aim to address privacy
challenges at a general level and avoid singling out the
afected health service providers in a negative light. To
adhere to ethical research practices, the chosen web services
are not referred to by their actual names but are denoted by
abbreviations WS1–WS10.</p>
      <p>In our test sequence, the browser cache was first cleared,
cookies were deleted, and then the front page of the health
service under examination was opened. On the front page,
all cookies and data collection were accepted. When using
the health service, all network trafic was recorded using
Google Chrome browser developer tools (DevTools). The
network trafic recordings were saved as HAR files (HTTP
Archive) for more detailed analysis. We manually examined
the log files, searching through the HTTP request payloads
and documented all instances of personal data meticulously.
Here we considered two distinct categories of personal data:
• Identifying data, capable of uniquely identifying
the website user, such as IP addresses, User-Agent
strings, and device-specific identifiers. Identification
may also happen with a combination of technical
details, including operating system or browser details,
window size, etc.
• Sensitive contextual data, for example an URL
address containing a sensitive search term used on a
medical website, or details on a booked appointment.
Although this kind of sensitive contextual data is
often contained in URL addresses sent to a third
party, it may also be elsewhere in the HTTP request
payload.</p>
      <p>What makes data leaks dangerous is the combination of
these two categories: identifying a user by e.g. their IP
address and then combining this to sensitive contextual data
such as details on doctor’s appointment. This enables third
parties to infer user’s potential medical conditions, for
example. It is also worth noting that while the identifying
personal data such as an IP address cannot always be
immediately combined to a person’s identity (real name), large
technology companies such and Google and Meta often have
the capability to fully identify the user, as users may use
the same device to login to the other services run by these
companies.</p>
      <p>Four common usage scenarios where the leakage of health
data to third parties is possible were recorded while using
the health services. The chosen scenarios were key
functionalities of the web-based health services that involved
processing of sensitive personal data, and the scenarios
varied based on the tested service. Network trafic was recorded
when 1) booking an appointment, 2) viewing personal
information, 3) using the search function, and 4) accessing
information pages.</p>
      <p>For the appointment booking scenario, network trafic
was recorded from clicking the appointment link on the
front page to the final stage of making the appointment. In
other words, the test was concluded before the final
confirmation of the appointment. In the appointment scenario,
an appointment was scheduled with a specific specialist
(such as a doctor or therapist). We also conducted a separate
test for booking an appointment for a specific procedure or
service (e.g. a COVID-19 test or influenza vaccination) if
such an option was available in the tested health service.</p>
      <p>The second scenario, viewing personal information, refers
to the section behind the authentication of the web service.
In this section of the web service, users can usually review
their own prescriptions, test results, vaccinations, or
previous appointments. In this scenario, we investigated whether
data leaks occur when the user displays diferent types of
personal information. For example, information about
laboratory results and previous appointments could potentially
be disclosed to third parties.</p>
      <p>We also examined the possible leaks when using the
search functions of the studied web services. The leakage of
search terms to third parties can be particularly dangerous,
because users may input highly sensitive terms, such as
the name of a specific disease or symptom. If user-defined
search terms are transmitted to third parties, these
external actors can possibly build a detailed profile of the user’s
assumed health status and medical history.</p>
      <p>The fourth usage scenario was related to information
pages within web services, often containing information
about specific diseases. It can be problematic if information
about the pages a user browses is sent to third parties, as
users can be profiled based on this. This can be especially
efective over a longer time period.</p>
    </sec>
    <sec id="sec-4">
      <title>4. Results</title>
      <p>Figure 1 displays information leaked to third parties on the
studied websites (December 2022). Each cell in Figure 1
indicates a leak of specific information type in a specific health
service. The numbers indicate how many third parties the
information was leaked to. For example, information about
initiating an appointment booking was leaked to 5 diferent
third parties in WS1.</p>
      <p>A common data leak pertained to the use of the
appointment booking function. Even though the appointment
booking process was not completed in this study, the information
about initiating this process indicates the user’s intention
to make a booking. In all services except for one (WS7),
information about initiating the appointment booking
process leaked to at least one third party. In three services,
details about entering specific stages of the appointment
booking process (e.g., selecting a time for the appointment,
entering personal information) also leaked. Leaking any
information about the appointment booking process is a
problem because it strongly indicates a relationship between
the patient and health provider. This kind of relationship
must be kept confidential according to the Finnish Deputy
Ombudsman1.</p>
      <p>Seven of the studied web services leaked additional
information about appointments to third parties. These included
the selected clinic location (3 web services), appointment
date (3), appointment time (1), the name of the specialist
(e.g., doctor) (3), the specialist’s field of expertise (2), and
whether the appointment was made as a private or
occupational health customer (2). The selected service (e.g.,
inlfuenza vaccination, COVID-19 test, or STD test) also leaked
on three of the studied websites. In one case (WS10), the
specific region (e.g., Central Finland) leaked instead of the
exact clinic location.</p>
      <p>The information transmitted to the third party about the
initiation of the appointment is problematic by itself,
because it implies a relationship between a patient and a
healthcare provider. Details about the reserved health service or
the doctor’s name reveal the nature of this relationship even
more precisely. It is also important to understand that a third
party can often track a specific individual’s online activities
over a long period of time. When multiple appointments
accumulate, a clear picture of the patient’s treatment measures
and health status begins to emerge.</p>
      <p>Figure 1 also shows how users’ searches were tracked.
Notably, in all seven cases where a health service website
had a search function, potentially sensitive search terms
were transferred to at least one third party, and in the worst
cases (WS4 and WS8), even up to four separate analytics
services.</p>
      <p>In all 10 examined health services, the URL addresses of
information pages opened by the user were delivered to at
least one third party. In the case of one service (WS2), the
URL was sent to six third parties. Of course, viewing an
information page about a specific illness does not necessarily
imply that the visitor has that illness or even suspicion of
it. However, the exposure of sensitive browsed pages to
multiple third-party analytics services is not favorable.</p>
      <p>Lastly, in our experiments we found no data leaks when
viewing personal information such as laboratory results
after logging in to the studied services. It seems these more
sensitive sections of the health services have been
implemented with the privacy-by-design approach in mind.</p>
      <p>To sum up, the findings of Figure 1 are concerning: for
1https://yle.fi/a/3-11213545
each examined health service, information leaked to third
parties either from the appointment booking page or search
function, in most cases, both. These pieces of information –
possibly combined with the pages the user browsed – can,
in just one visit, give a third party an accurate picture of the
user’s current health.</p>
      <p>Figure 2 shows the most common third parties (two
instances or more) present in the studied health services in
December 2022. Google Analytics and Meta Pixel were the
most common ones, Google appearing in every single
service and Meta in 8 services out of 10. The average number
of third parties per health service was 5.2, which we
consider a large number in websites processing such sensitive
data. WS1 had a staggering 9 third parties, WS2 and WS6
following close behind with 8 third parties.</p>
      <p>After discovering the data leaks in December 2022, the
studied healthcare providers were informed about the issue.
Figure 3 shows the updated status of data leaks in February
2024. The number of data leaks has decreased. For
example, calculating the sum of all data leaks in Figure 1 yields
116, while this sum is 70 in Figure 3. However, this number
is still very disappointing. Figure 3 shows clearly that
revealing the initiation of the appointment booking process,
and leaking viewed pages and search terms to third parties
are still a significant issue in majority of the studied health
services, although the number of leaks has gone down. It
is also surprising that highly sensitive information such
as the selected health service or the name of the specialist
the patient is going to see is still being leaked. Only a
single service, WS5, has completely removed third-party web
analytics and eliminated data leaks.</p>
    </sec>
    <sec id="sec-5">
      <title>5. Discussion</title>
      <p>
        While the sensitivity of the data leaked by studied services
ranged from visited information pages (not so sensitive) to
details on booked appointments (highly sensitive), this data
is still often directly related to the visitor’s health status [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ].
Also, even though the dataset we collected for the current
study is not large in quantity, the finding that all of the
analyzed web services leaked personal data to third parties
cannot be simply dismissed. Although the situation has
improved with time, web-based health services in Finland
still appear to have many privacy challenges. Regrettably,
it is highly likely that these issues extend well beyond the
scope of the websites we examined.
      </p>
      <p>
        Compared to many other studies (e.g. [
        <xref ref-type="bibr" rid="ref5">5</xref>
        ]), we found a
high number of data leaks and observed these data leaks
were widespread among the services we studied. One
reason for this is likely to be diferent data collection methods.
While many previous studies use automatic collection
methods, we analyzed the network trafic and data leaks manually.
Also, the other studies may not consider all the same data
items our study does. Our goal was to consider all
contextual data items that may relate to the user’s health status.
Some previous studies may only include the most sensitive
data leaks like leaking laboratory results and medications
and possibly exclude appointment booking related
information, for example. Therefore, our set of studied data items
and included use scenarios was more extensive than in most
studies, which afects the numbers of found data leaks.
      </p>
      <p>The use of third-party analytics is very dificult to justify
on web-based health services. While we strongly believe
the studied web-based services have not leaked sensitive
personal data intentionally and while the third parties may
not abuse it, the fact this data is sent to third parties remains
a concern. There are multiple precautionary measures web
developers and website maintainers should adopt to prevent
such leaks.</p>
      <p>
        A convincing argument can be made that third-party
web analytics do not belong to websites processing
sensitive health data. A straightforward alternative would be
eliminating third-party analytics entirely. In the cases web
analytics are necessary, locally hosted services like Matomo
[
        <xref ref-type="bibr" rid="ref16 ref17">16, 17</xref>
        ] should be used. With the use of such self-hosted
analytics, the health service provider now has full control
over the collected data and there is no need to transfer it to
a third party.
      </p>
      <p>If third-party services really are necessary, chosen
services should be thoroughly assessed and their use should be
carefully justified. Of course, there are some well-justified
use cases for trusted third-party services such as chat
services or appointment booking systems that are vital for the
functionality of the web-based health service. On the other
hand, third-party analytics cannot be deemed essential for
the functionality of web-based health services to the same
extent.</p>
      <p>During the software testing phase, a careful assessment of
data leakages to third parties should be conducted, similar to
the approach taken in the current study. In this examination
of outgoing network trafic, special attention should be paid
to pages that handle sensitive data, such as appointment
bookings pages. Analyzing network trafic gives developers
an accurate understanding of the data third parties collect.
This analysis also helps website administrators in
deciding which third-party services should be excluded from the
service altogether. It is worth noting developers may
unknowingly incorporate third-party analytics into websites,
as of-the-shelf platforms commonly ofer easy integration
options or include them by default. This is why a network
trafic analysis is essential.</p>
      <p>A good understanding of the application area, such as
the healthcare sector, holds great significance. The
development team should aim to gain knowledge about the privacy
regulations governing this particular industry. Efective
communication with stakeholders is important in order to
understand the requirements for protecting sensitive health
data. When talking about essential online services such as
medical center websites, the implemented service should
also undergo an external privacy audit.</p>
    </sec>
    <sec id="sec-6">
      <title>6. Conclusion</title>
      <p>Our alarming discoveries should urge software developers
and data protection oficers overseeing web-based
healthcare services to carefully assess the used third-party
services and adopt a privacy-by-design approach. Developers
and administrators of web services have to acknowledge
their responsibility in protecting sensitive customer data
and following fair data processing practices. The nature of
processed personal data and the involved third parties have
to be transparently communicated to users. When it comes
to web-based medical services, it is unreasonable to rely on
external services that may collect sensitive data. Failing to
address serious data leaks, such as the ones presented in
this study, increases the vulnerability of specific user groups
online, especially in terms of privacy. Users of web-based
health services should be able to see these websites as
trustworthy and confidential equivalents to traditional onsite
healthcare.</p>
    </sec>
    <sec id="sec-7">
      <title>Acknowledgments</title>
      <p>This research has been funded by Academy of Finland
project 327397, IDA – Intimacy in Data-Driven Culture.</p>
    </sec>
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