While its member organisations extend beyond the following local health and social care economies, the Regional Health and Social Care Information Sharing Agreement primarily serves:

  1. Buckinghamshire Oxfordshire and Berkshire West ICS;
  2. Frimley ICS; and
  3. Surrey Heartlands ICS (where the Surrey Heartlands ISA is a derivative of the Regional ISA at the time of writing).

Together these ICSs serve over 3.5m residents across 19 local authorities and around 450 health and social care providers (including approximately 350 practices) - all of which are participants in the various local shared care records.

The local shared care records

There are three main types of shared care record in place within the three ICSs.  These are:

  1. Arrangements based on specialised clinical systems such as:
    - Diagnostic imaging
    - Pathology;
  2. Electronic Patient Record (EPR) systems such as:
    - General Practice systems that that been configured for use by multiple partners
    - Trust’s internal systems that have also been configured for use by multiple partners; and
  3. The traditional shared care record systems themselves that pool data from multiple sources into a single broadly accessible repository for both direct care and analytics purposes.

To confirm their lawfulness, the data sharing and processing arrangements represented by the shared care records have been subjected to extensive scrutiny by local subject matter experts.  The arrangements (with a particular emphasis on Graphnet-based solutions) have also been subjected to scrutiny by solicitors and by Kings Counsel and in general both have confirmed that the arrangements are suitably lawful and robust.

Connected Care and TVS

Connected Care began as the name for the Graphnet supplied shared care record solution that is now in use to support patients and residents across Berkshire, Buckinghamshire, Farnham, North East Hampshire and Surrey Heath. As the pivotal processing arrangements are the same for both Connected Care and the Thames Valley and Surrey Care Record (TVS), the statements that follow also apply to the TVS processing.

Connected Care now comprises the shared care record as well as an analytics solution that is known locally as Connected Care System Insights. While System Insights offered considerable value before the COVID pandemic hit us, it has been an incredibly important tool in helping us to address the pandemic pressures as well as our subsequent work on system recovery. Furthermore, as we move beyond dealing with the pandemic, System Insights is pivotal to our ability to bring insightful, evidence based and innovative solutions to our work establishing an Integrated Care System.

The opinion summaries

In 2019, Solicitors and King’s Counsel carried out a review of our local arrangements (including our legal bases for the processing) and observed that arrangements are fit for purpose and that communications and engagement are robust and wide-ranging. (A copy of this opinion summary can be found here https://regisa.uk/documents/2019QCopinion.pdf).

Solicitors confirm that this opinion continues to apply (https://regisa.uk/documents/2023DACBopinion.pdf) which means that our current legal bases for processing remain consistent and compatible with data protection legislation and common law.

Solicitors also confirm the lawfulness of our approach to the provisioning of and access control for: anonymous data (for planning and system management); pseudonymous data (for managing cohorts); and identifiable data (for direct care) https://regisa.uk/documents/2023DACBdatamartOpinionFinal.pdf.

In late 2022, we again approached Counsel and instructed him to review and advise on the lawfulness of our approaches to four specific topic areas where analytics are performed for direct care as well as other (secondary) uses. These are:

  1. Our approach to pseudonymisation and anonymisation;
  2. Our approach to the processing of data for risk stratification;
  3. Our approach to the processing of Secondary Uses Service (SUS) data; and
  4. Our application of the National Data Opt-out.

Counsel supports our position on these topics and brief summaries of Counsel’s advice in respect of the above can be found at https://regisa.uk/documents/2023KCopinion1.pdf and https://regisa.uk/documents/2023KCopinion2.pdf

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