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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:
- Buckinghamshire Oxfordshire and Berkshire West ICS;
- Frimley ICS; and
- 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:
- Arrangements based on specialised clinical systems such as:
- Diagnostic imaging
- Pathology; - 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 - 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:
- Our approach to pseudonymisation and anonymisation;
- Our approach to the processing of data for risk stratification;
- Our approach to the processing of Secondary Uses Service (SUS) data; and
- 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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Status:
- “Received” = signed documentation has been received.
- “Sent” = documentation has been sent for approval but signed documentation has NOT been received in return. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Reissued” = documentation has been sent on multiple occasions for approval but signed documentation has NOT been received in return. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Reapproval required” – During the transition to agreements running through to the revised Regional ISA end date of 2028, additional statuses are necessary for documents that have previously been signed but which need reapproval.
- “Required” – During the transition to agreements running through to the revised Regional ISA end date of 2028, additional statuses are necessary for new documents that relate to joint processing and sharing that has previously been approved.
- “Hold” = the arrangement has not been issued for approval. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Planned” = the arrangement has not been issued for approval. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Active” = the processing that is described by this documentation is approved by the data controller(s) concerned as part of another document set. The processing is uniquely described here for transparency.
- “Cancelled” = the arrangement has been issued for approval. However, the processing requirement was withdrawn before approval by the data controller(s) concerned and the approval request was cancelled. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Withdrawn” = the arrangement was previously issued for approval. However, the processing requirement was withdrawn before approval by the data controller(s) concerned and the approval request was cancelled. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Declined” = the arrangement was previously issued for approval. However, the processing requirement was rejected by the data controller(s) concerned. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Rejected” = the arrangement was previously issued for approval. However, the processing requirement was rejected by the data controller(s) concerned. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Expired” = the arrangement was previously issued for approval. However, the processing requirement was neither accepted nor rejected by the data controller(s) concerned and after 12 months the approval request automatically expired. The processing that is uniquely described by this documentation is not approved by the data controller(s) concerned.
- “Discontinued” = the arrangement was previously issued for approval. However, the processing is no longer required and the processing that is uniquely described by this documentation is no longer approved by the data controller(s) concerned.
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The classes of member organisation within the Regional Health and Social Care Information Sharing Agreement are:
- General Practice organisations;
- Independent sector health care providers, including:
- Community pharmacies
- Community health service providers
- GP alliances and federations
- Hospices
- Mental health service providers
- Nursing home service providers
- Out-of-hours service providers
- Specialist health service providers
- Independent sector social care providers (adults and children);
- Adult social care providers
- Childrens social care providers
- Residential care service providers; and
- Local authorities;
- NHS Integrated Care Boards;
- NHS Trusts, including:
- Acute service providers
- Community service providers
- Emergency services
- Mental health providers
- Specialist service providers; and
- Voluntary sector providers (commissioned or coordinated by Local Authority and NHS organisations).
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Schedule C - Joint Processing and Sharing Arrangements
The Joint Processing Arrangements page has moved https://www.regisa.uk/documents/schedc.html
End of Schedule C
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Schedule E - Membership Register
The Membership Register page has moved https://www.regisa.uk/documents/schede.html
End of Schedule E
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Schedule D - Other (Secondary) Uses Processing and Sharing Arrangements
The Other (Secondary) Uses Joint Processing Arrangements page has moved https://www.regisa.uk/documents/schedd.html