OUR VISION

Changes to the Health and Social Care Act on April 1, 2013 affected the laws around the flow of personal confidential data (PCD).

New information governance regulations stated that only the Health and Social Care Information Centre (HSCIC) is able to receive and process PCD for commissioning purposes without patient consent.

These changes placed restrictions on how Clinical Commissioning Groups (CCGs) could implement and evaluate their strategic objectives and monitor and evaluate some of their commissioning activities.

NHS England sought permission from the Confidentiality Advisory Group to allow CCGs and Commissioning Support Units to have access to PCD for a limited range of commissioning uses until details of the new environment are fully defined.

CCGs can still receive PCD to support direct patient care but if they want to use PCD for commissioning purposes they must become an Accredited Safe Haven (ASH) or have patient consent.

ASH status allows organisations to legally process data in ways that prevent the identity of individuals from being identified. This data may include a single identifier such as the NHS number or postcode.

To attain ASH status, CCGs needed to achieve Level 2 of the HSCIC’s information governance toolkit by October 31, 2013.

GMCSU was commissioned by Bolton CCG, Salford CCG and North, South and Central Manchester CCGs to help them with their submission for ASH status.

The IG team worked closely with CCG clients to pull together a significant amount of evidence to demonstrate that the CCGs were able to attain Level 2 of the HSCIC IG toolkit.

This involved:

• Establishing an IG management framework
• Review, approval and publication of all IG related policies and procedures
• Ensuring procedures are in place for dealing with Subject Access and Freedom of Information requests
• Establishing and monitoring IG awareness and mandatory training programmes
• Establishing procedures for incident management
• Ensuring personal data is only used where there is a legal basis to do so
• Confirming all new processes and systems are developed and implemented in a secure and structured manner, complying with confidentiality and data protection requirements.

GMCSU also developed an action plan detailing the tasks that the CCGs needed to undertake to achieve the necessary rating by this date. This involved putting a data sharing agreement in place and obtaining a signed data-sharing contract as required by HSCIC.

Despite the deadline being brought forward in an already extremely restricted timeframe, GMCSUs IG team successfully delivered the submission on time, enabling the CCGs to be considered for ASH status.  GMCSU also applied for ASH status at the same time, so it could continue to effectively support CCG clients.

GMCSU’s IG team enabled Bolton, Salford and North, South and Central Manchester CCGs to successfully complete Level 2 of the HSCIC IG toolkit - in just six months. This means that the CCGs can now legally process PCD data and extracts from the HSCIC to support their commissioning purposes.

The Greater Manchester CCGs are five of only 26 CCGs nationally to have achieved ASH status. GMCSU also achieved ASH status and can now continue to support CCG clients.

 Grace Birch, Associate Director of Outcomes Delivery and Business Support, at Bolton Clinical Commissioning Group, said:

“Bolton CCG has now received its interim ASH status. This has been the result of great partnership working between the CCG and the GMCSU Information Governance team. Both teams put in an incredible amount of effort, with the GMCSU team providing us with invaluable support and knowledge.

“The introduction of the new Health and Social Care Act and the resulting restrictions placed upon the flow of PCD to CCGs caused a huge wave of concerns in Bolton. There are a number of CCG initiatives that have been developed in partnership with local member practices, which are key to the delivery of local objectives and the local vision of an integrated health and social care system. Being able to access patient data as an ASH will now enable this important work to progress, whilst keeping us compliant with the legal framework.”