Background
Under the Act (2025:170) on the Obligation to Provide Information to Law Enforcement Authorities, public agencies and certain other bodies must, upon request, disclose a natural person’s contact details to a law enforcement authority whenever those details are needed in law enforcement activities. The duty yields only when a confidentiality or professional-secrecy rule applies and “extraordinary reasons” (synnerliga skäl) indicate that the protected interest outweighs the interest in disclosure.
The Swedish Police Authority (Polismyndigheten) requested that Karolinska University Hospital disclose contact information for a specific individual. The hospital — noting that the only contact detail it held was the person’s phone number — refused. It offered two grounds: first, that the police had not demonstrated a law-enforcement need; second, that the information was covered by healthcare secrecy and extraordinary reasons favored non-disclosure. On the latter point, the hospital explained that the individual was receiving treatment for a contagious disease requiring repeated hospital contact, and that disclosure of the number risked causing the person to stop attending, thereby interrupting life-necessary treatment and potentially spreading a societally dangerous disease to others.
The Administrative Court of Appeal (Kammarrätten i Stockholm) dismissed the police appeal in December 2025. While it accepted that the police genuinely needed the number for law enforcement, it held that the hospital had advanced sufficiently concrete arguments that disclosure would deter the patient from seeking care. It further reasoned that requiring more concrete proof would risk exposing even more sensitive personal health details, and that the life-critical nature of the treatment tipped the balance toward non-disclosure.
The Court’s Holding
The Supreme Administrative Court reversed and ordered Karolinska University Hospital to hand over the requested phone number. The court began by emphasising the legislative intent behind the 2025 Act: agencies are expected, as a starting point, to share all relevant contact information with law enforcement, and the disclosing body is entitled to assume that the information is needed for law enforcement purposes when a request is made. The severity or scale of the underlying criminal conduct is not a factor in the balancing exercise for contact details.
On the “extraordinary reasons” exception, the court held that the threshold is deliberately very high. A phone number is not inherently sensitive personal information. For the exception to apply where disclosure might deter someone from seeking care, there must be concrete circumstances pointing with considerable force to that consequence in the specific case. Purely typological or general arguments — that patients of this kind tend not to seek care after police disclosure — are not sufficient. Moreover, the feared consequence must itself be of a serious enough nature to qualify as extraordinary.
The hospital had offered no case-specific facts meeting that standard. The court therefore found that extraordinary reasons in favour of protecting the secrecy interest had not been established, and that the statutory duty to disclose applied without exception.
Key Takeaways
- The “extraordinary reasons” exception to the duty to disclose contact information to law enforcement is deliberately narrow; refusal should be the exception, not the rule.
- Concrete, case-specific evidence of serious harm is required to invoke the exception — abstract or typological risks that disclosure “could” deter care-seeking are insufficient.
- The seriousness of the alleged crime is irrelevant to the balancing test for contact-information requests under the 2025 Act.
- Healthcare secrecy under Chapter 25, Section 1 of the Public Access to Information and Secrecy Act (2009:400) does not automatically block disclosure of a phone number to law enforcement; it merely triggers the balancing exercise.
- The court noted in passing that healthcare personnel are already unconditionally obliged under the Patient Safety Act to confirm whether a person is present at a healthcare facility when police ask — reinforcing the legislature’s general preference for law enforcement access.
Why It Matters
This is the Supreme Administrative Court’s first authoritative interpretation of the “extraordinary reasons” balancing test in the Act (2025:170), which entered into force in 2025 and significantly expanded agencies’ information-sharing obligations toward law enforcement. By insisting on concrete, case-specific evidence and rejecting generalised public-health arguments, the court has set a high and predictable threshold that will govern how hospitals, social services, and other bodies respond to police requests across Sweden.
The decision also carries implications for the tension between public-health policy and criminal investigation. Hospitals treating patients for serious communicable diseases can no longer rely on the general premise that police contact disrupts care as a sufficient ground for withholding a phone number. Agencies wishing to invoke the exception will need to articulate particularised facts about the individual patient and the specific risk of care disruption — a demanding standard that keeps the door open only in genuinely exceptional circumstances.