Despite the benefits that the use of electronic health records (EHR) provides for doctors, other healthcare professionals and researchers, people have genuine privacy concerns that their data might be leaked or accessed by unauthorised parties. This paper investigates and compares security measures that are implemented in three countries namely Denmark, England and Australia, to protect EHR systems.A comprehensive analysis of literature (including official documentation of EHR in the three countries) was conducted to identify countermeasures related to the technologies, policies and human factors that implemented in Denmark, England and Australia to safeguard their EHR. The findings of this paper highlight the importance of adopting a more holistic approach where strong policies and practices are implemented, and cyber security awareness and training are provided to the users of the system. Such approach will address people privacy concerns and increase their trust in using EHR. The comprehensive analysis has revealed countermeasures implemented to protect EHR in three countries. It shows that more focus needs to be given to users training and awareness to prevent any human related security incidents.