We provided the North Staffordshire GP Federation with vital resource and operational support ensuring project set-up within the specified timeline.
Background
North Staffordshire GP Federation is a membership organisation for all 76 GP Practices serving the whole of North Staffordshire. The federation has commissioned NHS Midlands and Lancashire’s (NHS ML’s) Information Governance (IG) Team to provide Data Protection Officer support services.
Stoke-on-Trent City Council and Stoke-on-Trent CCG have commissioned the federation to provide a health care support service to the homeless. The service will be operational from Brighter Futures in Hanley and the support workers (a nurse practitioner and a health care assistant) are employed by the federation. Health information would need to be shared with other organisations (City Council, The Police, Housing, Brighter Futures, and any third sector housing associations) along with sharing with the registered GP of the homeless person. The acute and mental health trusts would also need to be partial to the sharing of this data, particularly in cases of high-volume attenders.
Action
We provided a named Data Protection Officer (DPO) and ensured accountability and key approvals were evidenced throughout.
As information on specific cases would be shared at cross-organisation multi-disciplinary meetings and recorded for accuracy, the confidentiality requirements were stipulated in the terms of reference for this group.
The success of the scheme is heavily dependent on effective data-sharing mechanisms. To ensure the federation understood its roles and responsibilities of the data sharing requirements of the project, our DPO advised that a Data Protection Impact Assessment (DPIA) would be required to clearly identify any risks to the rights and freedoms of the individuals concerned, followed by the production of a Data Sharing Agreement to hold all organisations accountable to the highest standards of use.
Our IG Business Partner for Primary Care then met with federation representatives to discuss all aspects of the process, the mechanism for sharing the data, the legal basis and the way to evidence accountability throughout. The DPO then reviewed the DPIA in line with current legislation and approved it.
Impact
All organisations involved in the scheme signed the Data Sharing Agreement, having ensured they fully understood the requirements in relation to the sharing of special categories of personal data. The process was handled with high levels of attention to detail and always ensured adherence to the data protection legislation. The process was made so much easier with effective, clear communication from both NHS ML’s IG Team and the North Staffordshire GP Federation, who throughout the process, remained committed to the requirements
Feedback
“We received excellent support…advice was hands-on, thorough, and timely which was a huge help in terms of the timescales we had for getting the project started. As a Federation we also purchase our Data Protection Officer service from NHS ML as do most of our member GP Practices – to support that there is training available and a regular newsletter so that we are operationally aware of what we have to do and any new requirements.”
Ian Gibson, Associate Director of Operations & Services, North Staffordshire GP Federation
Further information
If you would like more information about our services, you can contact us on mlcsu.ig@nhs.net