In this blog, I will be looking at our proposals for ‘accredited safe havens’.
So far, we have received over 70 comments on the consultation. These comments are from members of the public, GPs, hospitals, care homes, commissioners, researchers, the voluntary sector and commercial organisations. Many of them are about our proposals for 'accredited safe havens'.
Every day, NHS managers – usually working in Clinical Commissioning groups (CCGs - the local organisations responsible for working out what health services people in in their area need and paying for their care) use information about patients to plan, monitor and improve health and care services. The uses to which information is put include:
- identifying who could be at risk of a condition or would benefit from a particular treatment
- making sure that NHS organisations receive the correct payments for the services they provide
- guiding decisions about how to manage NHS resources, so that they can best support the treatment and management of illness for all patients
- finding more effective ways of preventing, treating and managing illnesses
- making sure that any changes or improvements to services reflect the needs of the local patients
Much of the time, NHS managers working in CCGs only need to use anonymous data to carry out these important tasks. Sometimes, though, that is not possible and they need to use data that could be used to identify individual people. For example, to identify people who are at risk, it might be necessary to use a person’s postcode or details of their age. Taking this information, together with other information about an individual, it might be possible to identify that person. So, to ensure that this type of information is always used in a legal way, anyone who wants to use it must have either the consent of the person whose data it is, or legal permission to use it without consent.
In the long term we want these managers to move to different ways of working – to, wherever possible, use anonymous data. Where that is impossible, we want people to be able to consent to the use of their data or, where consent is not possible or impractical, for managers to access people’s data only through a safe environment that is legally accredited to handle personal data. In time, we would want that safe environment to be the Health and Social Care Information Centre. We are working on our plans to make these alternatives a reality but these better ways of working are not ready right now and NHS managers might still need access to some of your information for the next few years
The arrangements that are now in place for NHS managers to access people’s data have been reviewed by an independent expert committee and approved by the Secretary of State for Health.
In the current consultation, we are seeking to improve further the controls and security measures around how personal information is handled. We are proposing that organisations who want to continue to use personal information will have to apply to become an 'accredited safe haven'. That is, a place where people’s data can be held and used safely and securely. We want there to be as few of these as is necessary for the NHS to carry out its work on behalf of the people it serves. The consultation document sets out our proposals for how we might ensure that we have the right number of accredited safe havens, with the right type of safeguards in place, to protect patients’ personal information.
The controls we are considering include strictly limiting who can access the information, strong security for the systems that are used to hold and process the information, annual reviews of the continuing need for this information and independent audit of whether they meet published standards of good information governance.
We also intend to limit what managers can do with the information. We propose that managers will be able to link information from more than one source, for example link information form several hospitals for patients who have complex conditions. We also propose that managers will be able to use this information to investigate the quality of care that patients have received, plan services to meet the changing needs of the local population, understanding risks to individuals and informing those responsible for their care and to ensure that the correct payment is made for the care provided.
We want views on
- how many accredited safe havens there should be
- our proposals on the controls on the use of information
- what we think NHS managers should be permitted to do with the information
- what penalties and actions should be available if the accredited safe haven breaks the rules
The consultation runs for another 10 days. I welcome formal responses on the website and your comments directly to this blog.
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