Dr Tozer said once its own Serious Incident investigation team identified concerns over 'patient safety and public protection' it had no choice but to refer the matter to the police.
She also confirmed that the police and General Medical Council referrals were not the decision of a single person and its own investigation involved looking through files and initial interviews.
Dr Tozer said that HSSD had now 're-framed and improved' Serious Incident policies and procedures, but said this was not in response to the Alderney case.
It instead followed the damning midwifery reports, the subsequent action plan and the GMC revalidation suspension.
The chief officer was responding to calls for a public enquiry, led by grieving families of patients involved, after the police investigation into the four deaths was concluded and 'no evidence of criminality' was found against GP Dr Rory Lyons.
'Where there are issues over public protection they have to be referred on,' she said. 'They have to be, they will be and we will continue to do so.'