INFORMATION GOVERNANCE,LOVE IT OR HATE IT!Norman PottingerInformation Governance Manager

Admin and Introductions

• Fire alarms

• Please turn off or silence mobile phones

• There will be a break for coffee

• No hand-outs but I will send the slides to Sam if you want a copy

Objectives

• To support the IG on-line training tool

• Give you some more “local” guidance

• Help you to understand wider implications of Information Governance

• Keep you and your employers out of jail!

• Answer (if I can) your questions

Quiz

• On your own or in pairs, or groups – your choice

• Just take ten minutes to do this

• We will discuss your answers at the end of the session

What is Information governance?• All and anything to do with information

• Data Protection Act

• Freedom of Information

• Caldicott (1 and 2)

• Human Rights

• Records Management

• Information Security

• Data Quality

Data Protection Act 1998• European Legislation

• 8 principles

• Covers Personal Data and Sensitive Data• Test!

• Define Personal Data• Define Sensitive Data

• Gives rights to individuals (Data Subjects)

• Responsibility is personal

First Principle

• “Personal Data shall be processed fairly and lawfully”• Fair processing notices• No surprises• Access to personal data must be restricted and appropriate

If you get it wrong• A member of staff working in a GP practice illegally looked at the records of more

than a thousand patients. As a result he was fined for a breach of the Data Protection Act.

• Total fine over £1000

• The Information Commissioner has fined an ex GP's receptionist for accessing a patients notes. The receptionist from a practice in Hampshire looked up details of her ex husbands new wife on a number of occasions.

• Total fine over £1100

• NHS England (formally the NHS Commissioning Board) are having to pay a £200,000 fine because NHS Surrey (whose services have moved to NHS England) failed to ensure that PCs they arranged to be "cleaned" by a third party were being sold on still containing patient identifiable information.

• An ex-employee of University Hospitals of Leicester NHS Trust has been convicted of computer misuse after inappropriately accessing patient records. They received a six-month custodial sentence.

Caldicott 1 and 2

• Caldicott review 1997• Reviewed use of and access to patient records• Established the role of the Caldicott Guardian• Original 6 principles

• Caldicott “2” 2013• Clarified the H&SCA 2012 in relation to PCD• Tasked NHS England and the HSCIC with providing more guidance

and clarity• 26 recommendations – all accepted by the department of Health• Added a 7th principle

Caldicott Principles• Justify the purpose• Don’t use patient confidential data (PCD) unless it is

absolutely necessary• Use the minimum that is necessary• Access to PCD should be on a strict need to know basis• Everyone with access to PCD should be aware of their

responsibilities• Comply with the Law

• The duty to share information can be as important as the duty to protect patient confidentiality

Information Security

• Principle 7 of the Data Protection Act• Appropriate technical and organisational measures shall be taken

against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

Information Security

• Password Controls

• Policies

• Locked cabinets

• “Hidden” VDU screens

• Secure e-mail

Passwords

Passwords are like underpants.

They should be changed regularly,they are best kept hidden, and they shouldn’t be shared.

Good or bad

• onedirection

• 1direction

• tbbbitw

• tN1bbitw

• Nj89219*nel(m,LKH

To save or not to save?

Data Disclosure

• Could be a criminal offence

• Easily Done

• Normally done by accident

Secure e-mail

• @anyhospital.nhs.uk

• @nhs.net

• @hotmail.com

• @gp-d82973.nhs.uk

Summary Care Record• Populate a central register of all patients

• Summary only (although enhanced data may be uploaded later)

• Available to all clinicians

• Primary use of data (for direct patient care)

• Patients can opt-out

Care.Data (HSCIC)• NOW DELAYED UNTIL OCTOBER 2014

• Populate a central record of all patients

• Contains full patient records (read coded items)

• Data is anonymised or pseudonymised within the HSCIC

• Links primary care to secondary care data

• Collection of data is given legal basis under the H&SCA

• Data is for secondary use (i.e. not direct patient care)

• GPs and Patients DO NOT have a legal right to opt out

Quiz

Let’s review the answers

Any Questions?