Victims of unauthorized disclosures of medical information have enjoyed strict protection by state and federal courts. This is because secrecy is considered a sacred requirement in order to foster honesty and cooperation between a physician and patient. Confidentiality is considered such a vital ingredient to the physician-patient relationship by the medical profession that it is addressed in the oath, which is a prerequisite to admittance into the field of medicine: "All that may come to my knowledge in the exercise of my profession or outside of my profession or in daily commerce with men, which ought not be spread abroad, I will keep secret and will never reveal." The assurance of secrecy is, thus, ingrained in public policy and medical ethics and not in the "archaic whims of the common law." The importance of this public policy and the confidentiality between physician and patient has increased the growing concern in Ohio and throughout the nation regarding the unauthorized release of medical information to third parties for approximately the last thirty years.
Kimberly Rathbone, The Strict Ohio Supreme Court Decision in Biddle: Third Party Law Firm Held Liable for Inducing Disclosure of Medical Information, 15 J.L. & Health 189 (2000-2001)