The same cannot be said for the average unprotected database scanner.
You probably don't bring all of your notes from your whole practice with you on the train to lose. If you do bring some of your notes with you and leave them on the train, there's a good chance they will be returned without being accessed by the returner, or be collected as trash, again with no access. Even if there is some access, it's less likely that they'll be widely distributed, because they'd need to be digitized or otherwise copied first, and that's a lot of effort.
If the person who picks up your notes on the train is nefarious or even maybe just curious and happens to know the people in your notes, there's potential for negative outcomes for your patients, but IMHO, the probability of a negative outcome for patients given an incident of unauthorized access is lower with paper records than digital records. I don't know if I can really opine on the probability of unauthorized access --- digital records open up the possibility of more effective controls on access than a filing cabinet; you can't audit which records were read when an authorized person opens a cabinet to get some records and looks around at others.
That's a quarter of a million people who never explicitly consented to their records being digitized in the first place given to someone who they've never met for them to just leave it somewhere to be stolen.
That's the difference in scale and consent of a digital record system and non digital.
Not a problem then?
The recent controversies about online (and even genAI) psychotherarpy have largely left many to suffer unaided, out of fear of hacking or selling of their most secret of secrets.
It's like if "automobiles" all had cell modems in them, ran some minimum viable functionality Swiss cheese security embedded software, could be remotely controlled from the Internet, and the only things keeping mass destruction at bay is the lack of documentation and the fact that individual humans generally don't want to hurt one another. uh, maybe I need a different example.
And nobody outside of Hacker News cares about any of that. All they care about is getting from point A to point B, never mind that ~1,300,000 people are killed by by crashes every year and that we're poisoning our planet with them[1].
It's possible that I chose them as an example deliberately and cynically, as opposed to pedantically.
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[1] Both of which are far more pressing concerns than some Martian super-hacker pwning my car, but it's all worth the convenience of not having to get into a bus, or on a train.