What is the test for obtaining access to a patient's medical records?

^1. Courts are required to "balance the following factors to determine whether the governmental interest in obtaining information outweighs the individual's privacy interest: (1) the type of information requested, (2) the potential for harm in any subsequent non-consensual disclosure, (3) the adequacy of safeguards to prevent unauthorized disclosure, (4) the degree of need for access, and (5) whether there is an express statutory mandate, articulated public policy, or other recognizable public interest militating toward access." Tucson Woman's Clinic v. Eden, 379 F.3d 531, 551 (9th Cir. 2004).