Information Sharing Protocol to Support the Implementation of Risk
Stratification
NHS Gloucestershire Clinical Commissioning Group & Gloucestershire General
Practices
GCCG CES–ISP001 Information Sharing Protocol
v0.1
Document Control
Date
Version
Author
01/12/12
2.0
A. Bonfield
07/12/12
0.1
B Cutts
17/06/13
0.1
S. Bishop
Comment
Initial draft produced
with kind permission of
South
Central PCT Alliance.
Modifications
made to
reflect local
Swindon
collaboration. made to
Modifications
reflect local
Gloucestershire
collaboration.
GCCG CES–ISP001 Information Sharing Protocol v0.1
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.
GCCG CES–ISP001 Information Sharing Protocol v0.1
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1. Introduction & Background
Gloucestershire Clinical Commissioning Group (GCCG) has procured from
Northgate and Sollis a risk stratification service that provides Gloucestershire
practices with the analytical tools required to support identifying patients or
groupings likely to be high utilisers of health care resources. The system does
this by analysing healthcare data and applying well evidenced predictive
modelling techniques developed by Johns Hopkins University.
In Gloucestershire the use of a Risk Stratification tool is supporting the offering of a
national Risk Profiling DES by NHS England. As part of the introduction of a
programme of risk stratification, GCCG will support General Practices to help:
• Understand the risk stratified health profile of their registered patients
• Predict and therefore anticipate their registered patients’ future healthcare
needs
• Plan for the clinical resources that might be required to best support them.
These improvements will help GCCG, General Practitioners and clinicians to
provide better care by more easily identifying patients who will benefit most from
timely pre- emptive i.e. preventative intervention, via Case Management.
Additionally examples may include the offer of telehealth/ telecare monitoring for
patients developing COPD / implementation of earlier medication review for
patients identified at increased risk of impaired renal function or falls.
To facilitate the required analysis, it is imperative that robust data sharing
agreements are put in place to ensure that practices can be confident that the data
which they hold in trust is processed securely on their behalf and presented back
to the practice for interpretation and action.
This Protocol, therefore,
is an overarching framework that identifies the
guidelines and principles under which sharing of information between the
signatories will be undertaken to ensure that data is managed according to
currently available best practice guidance on the protection and use of confidential
information.
This Protocol will be supported by Subject Specific Information Sharing
Agreements (SSISAs) namely the:


ACG User Request Proforma
EMIS Web Apollo Supplier Extraction Consent Form
Each of the above detail by dataset the items to be shared and the associated
controls around their use and management, also detailed within the body of this
document.
This document has been developed to be read in its entirety, it should be a publicly
available document, accessible from each organisation’s web site.
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2. Purpose of the Protocol
The purpose of this Protocol is:






To identify the “categories” of information that are covered by this agreement;
To set out the principles which underpin the sharing of information.
To confirm the legal framework obligations for the secure sharing of
confidential information.
To identify the process for initiating the sharing of datasets.
To set out the responsibilities of all parties involved in this programme.
To identify the governance arrangements in place to manage and
maintain this Protocol
3. Information covered by this Protocol
This Protocol refers to all information, in whatever form that is shared between the
GCCG and General Practices.
Data provided would constitute use under the “Healthcare Medical” and “NonHealthcare Medical” purposes as defined by the Connecting for Health document
NPFIT-FNT-TO- BPR-0023.01, “Pseudonymisation Implementation Project (PIP)
Reference Paper 1, Guidance on Terminology” dated 20/11/2009 – see table 1
below;
Table 1 – Terminology
Term
“Healthcare Medical Purpose”
“Non-Healthcare Medical Purpose”
Description
Includes;
the
uses
which
directly
contribute to the diagnosis, care and
treatment of an
individual and the Audit/Assurance of the
quality of healthcare provided. In these
cases person
identifiable data can be used, but only
the minimum amount of data should
be used, and appropriate safeguards
should be the
in Management of Health
Includes;
place
Care
.
Services
(PbR,
World
Class
Commissioning). In these
cases
generally
“effectively
anonymised” data should be used,
unless consent has been gained from the
patient
or
there
are
special
circumstances, such as an overriding
public interest, or a route such as via
Section 251 of the NHS Act 2006 or the
Health Service (Control of Patient
Information) Regulations 2002.
GCCG CES–ISP001 Information Sharing Protocol v0.1
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“Effectively Anonymised”
Data from which the recipient is unable to
infer the identity of an individual without the
application of unreasonable effort.
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4. Key Principles
The parties recognise the importance of sharing information with each other in
line with this Protocol and the law and agree to co-operate fully with each other in
that respect.
The parties agree to share information in accordance with the Data Protection
Act 1998 and the Caldicott guidelines on the protection and use of patient
information.
For ease of reference, these are summarised below:
The Data Protection Act 1998 provides that data should be:
•
•
•
•
•
•
•
•
fairly and lawfully processed;
processed for specified and compatible;
adequate, relevant and not excessive;
accurate;
not stored for longer than is necessary;
processed in line with the relevant individuals' rights;
secure; and
transferred only to countries with equivalent legal and other
protections. The Caldicott Guidelines reflect those key principles:
• Justify the purpose(s) of using person-identifiable and
confidential information;
• Only use it when absolutely necessary;
• Use the minimum that is required;
• Access should be on a strict need-to-know basis;
• Everyone must understand his or her responsibilities; and
• Understand and comply with the law
GCCG will ensure compliance with these principles and the ESSA agreement in
place.
5. The Legal Framework
Each signatory to this Protocol undertakes that it will adhere to the legal
principles outlined in the ESSA when considering the sharing of information.
These are listed here for convenience:
•
•
•
•
•
•
•
Human Rights Act 1998
Data Protection Act 1998
Access to Health Records Act 1990
The Freedom of Information Act 2000
The Environmental Information Regulations 2004
Caldicott Guardian Manual 2006
Confidentiality NHS Code of Practice 2003
GCCG CES–ISP001 Information Sharing Protocol v0.1
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•
•
The Common Law Duty of Confidentiality
The NHS Information Governance Toolkit
Organisations must amend their Data Protection Act registrations to record the fact
that Northgate and Sollis will be acting as Data Processors.
Additional legislation may need to be referenced when sharing specific
information; this will be set out in the relevant SSISAs as required.
6. Procedure for Sharing Information
In so far as possible, information will be pseudonymised before it is processed
and care should be taken to ensure that pseudonymised data, whether alone or
when read together with any other information in the possession of the
recipient, does not identify an individual either directly or indirectly (i.e. to ensure
that it is “effectively anonymised”).
Where it is not possible to use effectively anonymised information, consent from
service users may be required. The parties acknowledge that any disclosure
without consent will need to be fully considered to ensure compliance with the law.
In order to facilitate the sharing of a specific dataset, a Subject Specific
Information Sharing Agreement (SSISA) must be completed and signed by the
nominated individuals from the relevant parties – see Appendix 2. This document
will identify the data items to be shared and the controls that will be in place to
ensure the security and confidentiality of those data items.
Once a SSISA has been signed, it must be returned with the necessary DES
documentation to the Primary Care Team within the NHS England Area Team,
where it will be formally logged and who will notify GCCG. The SSISA
documentation must be sent to GCCG who will then forward the SSISA to
Northgate/ Sollis who will facilitate the undertaking of the SSISA with the principles
set out within this document and the requirements of the SSISA.
After the data has been provided to the Northgate Data Centre, the CCG
Information Governance Team will monitor the adherence of the details of the
SSISA in relation to the use and lifecycle arrangements for the dataset.
It should be noted that no data will be shared unless a signed SSISA has been
received by the CCG.
7. Responsibilities
NHS GCCG and General Practices



Confirm that the NHS GCCG Caldicott Guardian will act as the lead
signatory in respect of this Protocol.
Ensure that Executive Leads, GP Practice Caldicott Guardians, Practice
Staff, Information Analysts and the Information Governance Team are
aware of this Protocol and the organisation’s responsibilities.
Ensure that there is a local procedure in place to expedite approval of
GCCG CES–ISP001 Information Sharing Protocol v0.1
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




requests for information sharing under this Protocol.
Ensure that where required, queries relating to requests under this Protocol
are identified and raised with the NHS GCCG Information Governance
Manager within 3 days of receipt of the request.
Ensure that appropriate training and information is provided to the
relevant members of their staff to ensure their compliance with this
Protocol and that compliance is effectively monitored.
Ensure that standards and procedures are in place for ensuring that, where
required, consent to disclose personal data constitutes informed consent
and is given freely.
Ensure efficient and effective procedures to address complaints relating to
the disclosure or use of personal data are in place.
Ensure where patient consent has not been provided to disclose personal
data, the relevant read codes should be applied by the GP practice within the
patient record, which will ensure the data is not included within the primary
care extract.
Caldicott Guardian – NHS GCCG


Act as the lead signatory on behalf of the GCCG.
Ensure that appropriate Information Governance assurances
undertaken on behalf of the GCCG and GP Practices; to include;
 Annual Northgate IG Toolkit Assessment
 External Audit of Northgate IG infrastructure
are
Information Governance Team – NHS GCCG




Act as the link between Northgate and the GCCG and GP Practices in
relation to all SSISA requests.
Ensure requests received are logged and monitoring arrangements put
in place
Co-ordinate the parties SSISA sign-off
Monitor the completion of IG Toolkit submission, external audit by Northgate.
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8. Governance and Compliance
This Protocol will be reviewed regularly by the Information Governance Group and
will include consultation with the GP Practices Caldicott Guardians.
The first review will take place 6 months after implementation and annually
thereafter. It will also be reviewed in line with updated or newly released legislation.
Any of the signatories can request a review outside of this agreed time frame if
they think it necessary and reasons are provided.
CSCSU will undertake to assess Northgate’s compliance with the Information
Governance Toolkit on behalf of the GCCG annually or as reasonably required
(including for instances where any breach of confidentiality has occurred in relation
to service users' personal data).
9. Toolset obligations
Table 2 – Description of Tools
Tool
ACGS
Purpose
Evidence Based Support
for
Risk Profiling, Predictive
Modelling, Resource
Allocation, Planning
Use
Healthcare Non-Medical &
Healthcare Medical
Technical and organisation measures and procedures
Northgate is required to ensure that at all
times:



it has appropriate technical and organisational measures against
accidental and unlawful destruction of data and loss, alteration, unauthorised
or unlawful disclosure or access to data;
it has adequate security programmes and procedures in place to
prevent unauthorised access or processing of data;
and provide the GCCG Information Governance Team with a written
description of these measures and procedures on request.
GCCG CES–ISP001 Information Sharing Protocol v0.1
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Appendix 1 ISP Agreement Signature Page
Please complete this form to indicate your acceptance of this Information Sharing
Protocol on behalf of your organisation.
ISP Reference:
Information Sharing Protocol between the NHS
Gloucestershire CCG and General Practices for the
supply of data to support Risk Stratification.
Organisation:
Address:
Phone:
Email Address:
Designation:
Signature:
Name (Please Print)
Date:
Once completed, please return this page only with the necessary SSISA forms
to Gloucestershire CCG (FAO: Sadie Bishop/ Wayne Douglas, Sanger House,
5220 Valiant Court, Gloucester Business Park, GL3 4FE)
GCCG CES–ISP001 Information Sharing Protocol v0.1
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Appendix 2: [Dataset Field Layout]
Diagnoses data from practice
system
Data Items
NHS Number
Sex
Date of Birth
Postcode
GP Practice Code
GP Code
Code Type
Diagnosis Code
Date of Diagnosis
Date entered into system
Prescribing data from practice
system
Data Items
NHS Number
Sex
Date of Birth
Postcode
GP Practice Code
GP Code
Code Type
Pharmacy code
Date of Prescription
Date entered into system
Format
an
an
yyyy-mm-dd
hh:mm:ss
an
an
an
an
an
an
yyyy-mmdd
hh:mm:ss
Format
an
an
yyyy-mmdd
hh:mm:ss
an
an
an
an
an
yyyy-mm-dd
hh:mm:ss
yyyy-mmdd
hh:mm:ss
Format (Identifiable /
Pseudonymised /
Aggregate) after load into
Northgate/Sollis system
Pseudonymised
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Format (Identifiable /
Pseudonymised /
Aggregate) after load into
Northgate/Sollis system
Pseudonymised
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
Identifiabl
e
20
Encounters data from practice system
Data Items
NHS Number
Sex
Date of Birth
Postcode
GP Practice Code
Encounter Type
Date of Encounter
Date entered into system
Long Term Conditions data from
practice system Data Items
NHS Number
Sex
Date of Birth
Postcode
GP Practice Code
GP Code
Code Type
Diagnosis Code
Date of Diagnosis
Date entered into system
Format
an
an
yyyy-mm-dd
hh:mm:ss
an
an
an
yyyy-mmdd
hh:mm:ss
Format
an
an
yyyy-mmdd
hh:mm:ss
an
an
an
an
an
an
yyyy-mmdd
hh:mm:ss
Format (Identifiable /
Pseudonymised /
Aggregate) after load into
Northgate/Sollis system
Pseudonymised
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Format (Identifiable /
Pseudonymised /
Aggregate) after load into
Northgate/Sollis system
Pseudonymised
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
Identifiable
21
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