RegISA Introduction
- Category: RegISA Introduction
The Regional IG Steering Group and the Regional ISA members held the 2023/2024 Regional ISA Annual General Meeting on the 12th March via Teams.
The link to the slides used in the meeting are here ((Regional ISA AGM slides)).
The purpose of the Regional ISA Annual General Meeting is to ensure that the Regional ISA members can have an authoritative say on the governance of the framework and the manner in which the framework is used to support joint processing and sharing arrangements across the Buckinghamshire, Oxfordshire and Berkshire West ICS, the Frimley ICS and the Surrey Heartlands ICS.
The agenda for the AGM was as follows:
- Welcome and introductions
- Declarations of interest
- Conduct of the meeting and check for priority AOB items
- Summary of the scope, status and membership of the Regional ISA
- Some of the benefits resulting from the sharing arrangements
- Future transformation and digital developments to be supported by the Regional ISA
- Onboarding of Surrey Heartlands controllers to support TVS in Surrey Heartlands
- Communications arrangements for TVS
- The s.251 (COPI reg.5) request to support Risk Stratification in TVS
- 2023/24 Key decisions made (decision log), policies agreed (Regional ISA Policies (https://www.regisa.uk/index.php/policies)) and progress with BOB IGSG
- IGSG Meetings and Membership:
- Quoracy and attendance (including nominations*** and election of members)
- Proposed quarterly Regional IGSG meeting dates and timings during 2024/2025
- The Timing of the 2024/2025 Annual General Meeting (currently planned for Tuesday 11th March 2025)
- Any other business
(*** Nominations are required for regular IGSG meeting members as well as the roles of IGSG Chair and ISA Administrator.)
- Category: RegISA Introduction
The Agreement
Every health and social care organisation in the country is identifying substantial requirements to share and use personal confidential data in order to achieve planned improvements in care delivery and in financial efficiency.
It is also the case that many opportunities to improve care are delayed or lost due to the challenges associated with designing and agreeing information sharing agreements on a project by project basis.
The regional Information Governance Steering Group (IGSG) which is chaired by the Chairman of the Berkshire Local Medical Committee at the time of writing manages the agreement and the membership of the agreement on behalf of the members. The Administrator (Frimley Health NHS Foundation Trust at the time of writing) maintains and publishes the agreement documentation and supporting schedules and registers on behalf of the member organisations and IGSG.
This agreement has been reviewed by Solicitors and by King's Counsel and in their opinions it is both lawful and fit for its purpose. Summaries of their opinions can be found at the Legal Opinion Summaries page.
This agreement builds on the success of the similarly structured prior agreements for the sharing of information for the provision of care and for secondary uses agreements in use since 2013 and replaces the current 2023 version of the agreement. The aims of the agreement are:
- To provide a clear framework for the secure sharing of personal confidential data for the delivery of care and for the management of the health and social care system (in particular in respect of data controller organisations' responsibilities in respect of GDPR art.26 (Joint Controllers);
- To accelerate the pace with which regional and local sharing requirements can be agreed; and
- To reduce the costs of developing and agreeing individual sharing requirements.
Very specifically, this latest iteration of the agreement is designed to better support the development of:
- Federated working and networks;
- Integrated working and care delivery models;
- Real time risk stratification at the point of care for patients with the most complex needs; and
- Latest guidance on data controllership resulting from the implementation of GDPR.
Each organisation remains responsible for the control and use of personal confidential data within the organisation as required by the legislation and the Schedule F and Schedule CDE Mapping pages are designed to actively support data controller organisations' responsibilities under GDPR art.30 (Records of Processing).
Structure of the Agreement
The Regional Health and Social Care Information Sharing Agreement is executed as a subscription agreement. This form of agreement allows controlled processing and sharing to begin as soon as two controllers have signed their sharing documentation. Unlike the traditional multi-party agreement models, processing and sharing does not need to wait until all parties have executed the agreement.
Organisations become members of the agreement by signing up to the master agreement that sets out the scope and terms of membership for the agreement as well as the roles of IGSG, Lead Controllers and the Administrator. The Administrator accepts the new member’s signed master agreement on behalf of the members as a whole.
A list of the various classes of organisation is presented in the Classes of Organisation page.
Implementation
Implementation of the agreement is as follows:
- Every member of the framework needs to sign the master agreement;
- The agreement is currently and will in future be presented through an electronic signature process as a single document;
- Data controller organisations that contribute data to the shared pool as a data flow or information asset are presented with one or more additional documents describing each specific processing and sharing arrangement the controller is expected to contribute to;
- Where the master agreement and one or more individual processing and sharing arrangement(s) are executed contemporaneously all documents are presented through an electronic signature process as a single document … with signatures required for each item requiring approval; and
- Where subsequent individual processing and sharing arrangements are executed non-simultaneously the documents are presented individually through an electronic signature process for approval.
Some supporting documents are presented below.
Current Master Agreement for the period 1st April 2022 to 30th April 2028
Note, both versions of the agreement documents are active during the transition. No material changes other than the effective dates have been made between the documents.
Below you will also find details of the Regional ISA membership.
See also:
Records of Processing - All processing and sharing arrangements
- Category: RegISA Introduction
On behalf of the Regional IG Steering Group and the Regional ISA members we have written to all local health and social care organisations that are members of the Agreement to provide stakeholders with details of the 2022/2023 Regional ISA Annual General Meeting.
The link to the Teams meeting is included in the email invitation.
The purpose of the Regional ISA Annual General Meeting is to ensure that the Regional ISA members can have an authoritative say on the governance of the framework and the manner in which the framework is used to support joint processing and sharing arrangements across the Buckinghamshire, Oxfordshire and Berkshire West ICS, the Frimley ICS and the Surrey Heartlands ICS.
The proposed agenda for the AGM is as follows:
- Welcome and introductions
- Declarations of interest
- Conduct of the meeting
- Summary of the scope, status and membership of the Regional ISA and the current joint processing and sharing arrangements supported and discussion of matters arising
- Discussion of the King’s Counsel opinion in respect of:
- Risk stratification
- Anonymisation and pseudonymisation
- The Regional ISA arrangements as a whole
- 2022/23 Decisions made and policies agreed
- Future joint processing and sharing developments to be supported by the Regional ISA
- Quoracy, membership, frequency and administration of the Regional ISA and the IGSG meetings:
- Quoracy requirements, attendance and delegation
- Meeting frequency
- Retiring IGSG meeting members (none notified to the chair)
- Nominations for new IGSG meeting members
- Election of new IGSG meeting members
- Nominations for Regional IGSG meeting Chairman
- Election of the Regional IGSG meeting Chairman
- Nominations for Regional ISA Administrator
- Appointment of the Regional ISA Administrator
- Matters arising from Regional IGSG meeting membership changes
- Regional IGSG meetings during 2023/2024
- The Timing of the 2023/2024 Annual General Meeting
- Any other business
We do hope that members will be able to join us on the 14th of March.
- Category: RegISA Introduction
To support data controllers with the joint processing and sharing arrangements several documents have been prepared.
The documents attached below include:
- Materials to support referrals to Multi-Disciplinary Teams (MDTs) and Integrated Care Teams (ICTs).
- Materials to support more general referrals.
- Posters that can be displayed in public areas.
- Leaflets that can be given to members of the public, patients and service users.
- An example display screen message that can be displayed in public areas.
Earlier public engagement activity
Earlier public engagement activity takes two forms:
- Members of the public (as represented by local healthwatch and public and patient engagement forums) are invited to and generally attend regular programme boards as well as assembly, council and members meetings where information governance matters and sharing arrangements are discussed.
- Around a dozen events involving the public have been held across the various health and social care economies covered by the sharing framework since 2016 in respect of the major interoperability and sharing proposals of the partner organisations.
Recent and planned public, patient and service user communications activity
Please see below a summary of the future (potentially annual) public, patient and service user communications activity:
- Mailing to all addresses including of a leaflet as part of the spring Council Tax mailings
- Emailing all NHS staff through organisation distribution lists
- Emailing all Local Authority staff through organisation distribution lists
- General Practice attendees
- The provision of posters and leaflets for GP surgeries
- Inclusion of message on waiting room screen
- A&E attendees and admissions
- Posters and leaflets on display
- Statements in discharge letters
- Articles in Trust magazines
- Posters in Secondary Schools
- Opportunistic public contact with the inclusion of a standard paragraph on all outgoing mail, signposting website for further information
Websites
Every data controller will have their own website for public, patient and service user communications. Examples of how joint processing and sharing arrangements are supported are provided by the following websites
- https://www.fhft.nhs.uk/your-visit/privacy-policy-how-we-use-your-information/patient-information/
- https://www.berkshirehealthcare.nhs.uk/protecting-your-data-privacy-notice/
- https://your-data-matters.service.nhs.uk/privacynotice