Information Governance Conference Call
11th October 2011 (10am – 12pm)
Introduction:
This conference call was arranged to discuss the specific local Information
Governance (IG) issues being experienced by the CAF demonstrator sites. IG was
one of the top 3 issues that sites asked to be included at the recent CAF network
event. It was felt that the subject could not be dealt with appropriately at the event
and it was therefore decided to hold a conference call with a panel of IG ‘experts’
who kindly offered to answer questions raised by sites and offer guidance and
potential solutions to issues.
Panel Members:
Jan Boucher
(Information Governance Officer Portsmouth City Council/CAFA 2 IG Lead - Consortium)
Chris Hardie
(NIGB Social Care Lead)
Beverley Carter
(Head of IG NHS Portsmouth / Registration Authority Manager)
Linda Chan
(Organisational Development Manager-Health & ASC, Southampton City Council)
Paul McMahon
(Records Manager & IG Lead, University Hospital Southampton)
Richard Allen
(Carer / CAF Team / Wiltshire PCT)
List of Attendees:
(Appendix A - attached)
Q.1
Adam Maddison, Corelogic
My main interest, as per my question at the CAF Network day, is regarding
local authorities’ corporate IT departments blocking Citizen access to their
data: how can we persuade obstinate corporate IT departments to get over
their issues and let Citizens access what is rightfully theirs?
Background:
We are working with Camden who have portal functionality, however, Camden
corporate IT department are concerned about opening the system up and making it
available to citizens. Are other authorities facing a similar problem?
National guidance would be helpful to state that if suppliers go through specified
stages then systems should be available for citizens to access.
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Discussion:
 What are the issues that the IT department have?
 It is the responsibility of the information asset register owner to make the
decision. The IT department should only ‘hold’ the information.
 IT systems have been in place longer than IG has had a higher profile – IT did
not have to consider IG when systems were put in place.
 It is difficult to get discussions between IT and IG in council – does Camden
have a corporate IG group?
 Has an impact assessment been done to open up the discussions?
Response from Panel:
The panel agreed that it was difficult for organisations to separate their IT function
from their business function and that more discussion was needed between IT
departments and IG. There is a balance between the need to share information to
provide a good service and customer experience versus the need for IT to ‘manage
the system’.
Portsmouth City Council has a corporate IG group which meets monthly and brings
together the Head of IT; the Caldicott Guardian etc which has proved very
successful.
It was also felt that the business case needs to be transparent so that IG is at the
forefront of a project to open up the dialogue at the beginning.
The panel members suggested that this question should be raised by the IG Lead in
Camden with the NIGB for further guidance.
It was noted that in respect of a national statement, the long awaited Information
Strategy which is due to be published in Winter 2011, is more likely to make specific
statements around user access to information.
Q.2
Robin Ingram, OLM
There is a requirement, both legally – DPA, and for CfH in the IGT that
organisations ensure that the subject is aware of what their information will be
used for, and how it may be shared. An extract from the Social Care view of
the IGT guidance 9-202 includes the following:
Using the Information for Purposes Unconnected to Care Services
Where an organisation wishes to disclose confidential personal information
for a purpose unrelated to care, consent cannot be implied. In most cases,
individuals should be asked for their explicit consent for information to be
shared with non-care organisations, for example:
• housing departments;
• education services;
• voluntary services;
• Sure Start teams;
• the police;
• government departments.
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Councils handle this in different ways, with some stating that the information
given will be used only for Social Care and will only be shared with other
departments or organisation after the express permission of the subject has
been obtained, other councils have a blanket statement to the effect that once
we have your information we will share it with other departments inside the
Council and other organisations such as Police and Voluntary sector if we
deem it appropriate.
This variation in approaches raises questions on information sharing. If a
Council with strict control gets a service user’s permission to share their
information with another council, what checks and controls do they put in
place to ensure that the service user’s expectations are met?
Background:
I work with a lot of different councils. The point is about being clear that
organisations or people you share information with observe the same
processes/practices that you do, otherwise you have guaranteed one thing to the
individual but how do you know the people you pass the information onto will do the
same?
Some councils are very prescriptive about who information will be shared with, whilst
others seem to be saying that they will share it as they see fit.
Discussion:
 Is this cross council sharing or cross organisation? It is unlikely that 2 councils
would be working with a person at the same time – transfer of cases is on a
need to know basis only.
 Situation of out of county placements will mean that 2 councils are involved
with a person.
 Principle of Data Protection Act says: ‘data shall only be obtained for one or
more lawful purposes and shall not be further processed in any manner
incompatible with that purpose or those purposes’. You need to tell people
what you are using their information for and get consent for it. Suggest when
sharing information with another agency that you agree at the outset what the
information shared can be used for and commit the other agency to this via a
written sharing agreement /protocol. The onus is then placed on them to only
use or further share information within the agreed framework.
 Commissioning organisations which put services in place rely heavily on
contracts to contain correct wording so people understand their obligations
under IG. Audits can be undertaken to make sure those obligations are met.
 There is a potential risk of causing harm to an individual if information is
shared in a way that has not been agreed with them – they will lose trust in
the organisation/person.
Response from Panel:
A panel member explained that in Southampton City Council an audit had been
carried out on how people share information. Southampton, Hampshire and
Portsmouth councils and a number of local NHS organisations are working together
and have agreed an overarching Information Sharing Protocol to allow them to share
information between the organisations.
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Southampton City Council work in partnership with Capita, in this arrangement they
fulfil certain functions as part of their contract, so if they breach IG they breach their
contract.
It was noted that consent is collected in various ways. In the CAFA2 project the
partners are working with the Southampton Overview Group (SOG), which consists
of service users and carers, to develop a ‘permission to share and view’ document.
This has been ratified by both the Hampshire and Portsmouth Overview Groups
(HOG/POG) and will form part of the CAFA2 products at the end of the programme.
This document could also be used for voluntary organisations/third parties.
The panel expressed concern about local authorities who might have a ‘blanket’
consent form and felt that the Information Commissioner would also have concerns
around this. They said it was important to understand why such a system was in
place and that it needed further investigation. The panel requested more information
about the ’blanket’ consent to share form and how it was explained to individuals,
noting that the Social Care Record Guarantee literature should be used to give
individuals a full explanation.
The panel suggested that Robin should send further information and the ‘link’ for the
council website to the NIGB for further investigation.
Q.3
Sue Cooper, NHS London
London has particular challenges around sharing information across wide areas and
between many possible permutations of health and social care organisations. In
summary, some areas in London have addressed information governance with
Subject Specific Information Sharing Agreements (SSISA) for secure email for
specific workflows. BUT, this approach has many down sides – not least that for
instance with the Admissions & Discharges workflow (Section 2 & 5’s) – hospitals
may need to talk to Boroughs from all over the country – getting them to sign up to a
local SSISA is unworkable but without their signature on that SSISA, technically
they’d still need to fax information through. We’re looking at a pan-London SSISA and
are working on exactly how “sign up” will work. Have any other areas taken this
approach and are there any examples of SSISAs that can be shared?
Background:
I work for the SHA covering all of London. We are looking at secure email,
particularly Section 2 and 5 workflows. e.g. if a person requires hospital admission
and they have social care needs then information needs to be sent to the appropriate
council. This means that a hospital might need to communicate with many boroughs
which can be difficult. We are therefore looking at a pan-London information sharing
agreement (SSISA) which can held on a website where all parties can sign up to it
and view it.
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Discussion:
 The CAFA2 project is developing a pan Hampshire agreement based on the
‘Trusted Organisation’ approach – offered to share this with NHS London
when signed off.
 Southampton City UHT has one overall agreement with local arrangements
included i.e. a separate protocol between each organisation but said this
would be difficult in London when dealing with lots of local authorities and
hospitals.
 Carl Evans said from a national position it felt like there was a lot of
duplication around this work and that within the CAF programme we could pull
the learning together as everyone is facing the same issues.
 The NIGB are keen to get good examples of consent forms; IG protocols etc
on their website. They are also looking at the IG toolkit to see if it can be more
social care focussed. They would like to put some of these issues as FAQ’s
on their website.
Response from Panel:
The panel agreed that there was duplication around this work and felt that it would
be helpful to have some examples of good practice and a ‘hub’ somewhere to hold
all the information together.
Carl suggested that at this time of budgetary constraints there may be some ‘wins’
around bringing all the learning together to provide some guidance. It was agreed to
discuss this matter further with the ADASS IMG group.
Q.4
Yarni Finney, Rochdale/CAF Co-ordinator
Retention of citizen portal record – is this the same as a social care record or as it
belongs to the individual, should they be able to keep it open for life e.g. the
interaction to the council just gets turned off if they are no longer eligible for or
receiving services?
Background:
I am interested to find out what the retention rules are between a local authority and
an individual using a portal to access their records.
Discussion:
 The record shouldn’t be held any longer than it is needed – it should be
governed by the existing records policy.
 What if an individual uses a council portal to amend their own record?
 If a professional is making a decision on it then it needs to be retained as long
as the main record.
 If a clinician is adding to the record then it needs to be retained as long as the
main record.
 A whole piece of IG needs to be put in place around who can make any
changes to a portal record.
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If a person has a citizen portal record, are the rules different to those who
have a social care record?
The definition of this type of record needs further clarification – it is new
territory.
If a portal is going to be left ‘open’ for as long as an individual needs it, it will
be ‘active’ and therefore retention is not an issue.
Response from Panel:
The panel felt that it was important to understand what a ‘portal’ means as each
scenario would be dealt with in a different way. The members thought that some
good practice examples would be good and Carl suggested that it might rely on
views from the Dilnot Commission as things begin to take shape.
It was suggested that in light of the issues discussed it would be good to have a
workshop specifically looking at citizen portals. Carl confirmed that the CAF Team
were looking into this and that it would be good to utilise the expertise of Jan
Boucher and the panel members around this work.
Q.5
Yarni Finney, Rochdale/CAF Co-ordinator
PDS issue: Service user tells GP one address but gives social care real address,
difference being so they can keep their GP even when move house. If the address is
updated by social care through PDS, what kind of issues would this cause and would
social care be supported in putting correct details when they didn’t ask the individual
if they could update them on the PDS?
Response from Panel:
The panel said that this was a very difficult area e.g. if an individual was under the
Witness Protection Scheme then there would be a different address on the PDS
system. Thought needs to be given to the trust between the local authority and the
individual, this would be broken if the authority simply changed the details held on
the PDS system, they would need to speak to the individual personally to establish
the facts.
It was agreed that this may not be an issue when restrictions around registering with
a GP are relaxed within the next year.
Q.6
Cheryl Martin, Isle of Wight
We would like advice on the IG aspects of establishing and using Citizens Portals in
the prison including consent to share and how this is collected.
Background:
This might be about prisoner’s human rights and not really an IG issue. Prisoners are
not able to access the internet within the prison for obvious security reasons, so any
consent would have to be collected by paper and scanned into their medical records.
It is a difficult process for prisoners to be able to view their own record.
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Discussion:
 Difficulty of the prison having to retain all the information that is sent to it
whilst trying to allow prisoners access.
 A portal will be very difficult to put into a prison – would need to work
alongside the prison authorities/Ministry of Justice to get ‘buy in’.
 Some barriers have been broken, can now view or record information on a
prisoner’s record.
 A citizen portal should not be the only way of accessing records. Online
access is an option but people can request to see their own written records.
 A prisoner’s record can contain significant 3rd party information which cannot
be shared for safety or security reasons so there are lots of issues/obstacles.
Response from Panel:
The panel agreed this was a difficult issue and offered the opportunity for Cheryl to
attend the Portsmouth IG Working Group meeting to discuss this matter further. Jan
Boucher will forward dates for the meetings to Cheryl.
Carl added that further advice should be sought on this issue from the Ministry of
Justice if it was felt that there are some benefits for being able to share information
via a portal. He offered to take this up at a national level.
Q. 7
Pete Thompson, OLM
With regard to Child Protection messaging or notification when a case is under
review, such as minutes of meetings etc. Currently this type of notification is handled
by admin clerks printing, photocopying and physically mailing paper between
agencies. There are clearly potential benefits for efficiency and IG in doing this
electronically. What particular IG requirements will need to be considered when
progressing with this?
Background:
We have had scoping meetings with Shropshire Council looking at Child Protection;
they are considering using the OLM system to share Child Protection
notifications/messaging. We would like to understand what IG requirements we need
to consider.
Discussion:
 A secure route is needed – for Health an nhs.net account; for local authority a
gsx account.
 Generally Child Protection information is held in a separate part of the system,
so it is not an open record.
 At a case conference there will be others present e.g. family, education so
minutes would still need to be sent by paper as not all would have access –
would need a good business case for doing this.
 It’s good to be thinking about IG at the beginning of the process
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Response from Panel:
The panel felt that it would be good to have some national guidance on this and
suggested that the Information Commissioner’s Office should be able to help with
this issue.
There were 3 people unable to dial into the conference and so 6 questions
were not covered on the call. The panel have kindly given their responses to
those questions below.
Q.8
Stephen Godfrey, Hampshire
A service user of mine has dementia and permanently lacks mental capacity to make
decisions. I would like to share a summary of the social care information about this
person on the local shared health system so that, if/when my service user requires
care and treatment, appropriate health staff in A&E/ambulance service/Out Of Hours
will be able to access this information (having assessed the best interests of the
individual in lieu of explicit consent to view the information) as it will almost certainly
be in the best interests of the care and treatment of my service user for them to see
this information quickly. Is it acceptable to share information in this way?
If it is not, under what circumstances would it be acceptable for me to make a best
interests decision to share?
Response from Panel:
In addition to the Mental Capacity Act 2005 any sharing of personal sensitive data
must also satisfy the requirements of the Data Protection Act 1998, Common law
duty of confidentiality and right to privacy under Article 8 of the Human Rights Act
1998. People lacking capacity are still owed a duty of confidence and therefore care
professionals will often need to make difficult decisions about whether to disclose
information and who are the appropriate people to disclose that information to.
Where a service user lacks capacity on a permanent basis a decision will need to be
taken to determine if it is in the individual’s best interest to transfer information on a
routine basis to the local shared health system.
The key principles of the MCA are as follows:
 People are generally assumed to have capacity from the age of 16 and
therefore it is for care professionals to demonstrate that an individual lacks
capacity to make the particular decision in question.
 Where capacity is in doubt, then the individual’s capacity must be assessed in
relation to the particular decision to be made.
 There is a duty to support individuals to make decisions for themselves where
possible.
 Where an individual lacks capacity not only should they be consulted about
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their wishes but there is also a duty to consult with their representatives (this
includes legal representatives, the individual’s nominated next of kin).
Where an individual’s capacity is temporarily impaired or fluctuates then,
where feasible, major decisions should be deferred until the individual can
make the decision for him / herself.
Having followed the above principles, or in emergency situations, care
professionals can make care decisions on best interests grounds about the
care of the individual.
If there is a legal representative for example named Lasting Power of Attorney or
Court Appointed Deputy, depending on their powers they may have the authority to
give consent on behalf of the service user and the views of family should also be
taken into consideration. The Mental Capacity Act Code of Practice should be
consulted as there is a hierarchy of people to be consulted Section 5.49
When reaching the decision all those involved for example social care professionals,
legal representatives and family should be fully aware of:
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The justification for sharing the information
The type of data that may be transferred for example care plans,
assessments, reviews etc (free text should be avoided as it is open to
misinterpretation out of context and may be excessively disclosive)
How the information will be used including the purposes
Which systems the information will transferring from and to
How it will be transferred and stored and the security measures in place
Who will have access to the information (organisations and staff roles rather
than named individual staff members)
How access will be monitored
How to opt out if it is no longer in the service user’s best interest; for example
if a service user is at risk and their identity needs to be protected
Consideration also needs to be given to whether to share information which has
been written for a particular context, as when transferred to other organisations there
is a risk the information could be misinterpreted.
(see http://www.rcgp.org.uk/pdf/Health_Informatics_SRPG_final_report.pdf
paragraph 5.7 & 5.8.)
It is important to consider therefore whether it would be more appropriate for a
summary to be shared, which has been created in the full knowledge that it will
shared across health and social care. Summaries written for sharing in a single
sector may not be appropriate to share more widely without being reviewed and
edited and staff contributing to the record should be aware that it may be shared.
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In general information should only be transferred when the representatives have
agreed the extent of the disclosure and the decision documented. Organisations may
wish to ask representatives to provide written confirmation of the documented
decision as evidence should the decision be challenged. The decisions of legal
representatives, provided it is within the scope of their authority, must be respected.
The views of next of kin should generally be respected but there may not be
agreement between them, in some instances, the individual will have expressed a
wish for information not to be disclosed to their legal representatives and/or next of
kin.
Robust procedures must be in place to ensure the decision to share is reviewed:
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Q.9
on a regular basis (at least once a year)
If the nature or extent of the data is changed
If access is extended to new roles
If the purpose of the sharing changes
When the service user’s needs change.
Jan Hoogewerf, Cheshire East
NHS and social care staff are working in joint teams, continuing to be employed by
one organisation, but accessing a shared assessment system and managers have
access to servers with corporate files of both organisations. The scenario is: an
employee working for organisation a) needs access to a system owned by
organisation b). Both organisations have the same levels of IG in place (i.e. both
using NHS IG toolkit), but IG are raising an issue:
‘If the employee of organisation a) abused their access to the system owned by
organisation b), then organisation b) would be liable, but would have no come back
against the individual as they did not employ them.’ Is this correct (doesn’t sound
like it is to me!)?
Response from Panel:
A number of Health & Social Care Teams have a legal framework through contracts
or a Section 75 Agreement for example Community Mental Health Teams and
Learning Disabilities Teams. Groups of staff who work as ‘joint’ teams, e.g. hospital
discharge teams and other multi-disciplinary teams have not been formed using the
same legal framework.
Sharing of personal sensitive data must satisfy the requirements of the Data
Protection Act 1998, Common law duty of confidentiality, right to privacy under
Article 8 of the Human Rights Act 1998 and Mental Capacity Act 2005.
Before any sharing can take place the legal implications must be considered and this
should include:
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What the sharing is meant to achieve
What information needs to be shared
Who requires access
When is should be shared
How it should be shared
What measures can be put in place to assess if its meeting its objectives
What risk does the data sharing pose
Could the objectives be met through other means or using anonymised data
In order for the processing of personal sensitive data to take place an organisation
must have the explicit consent of the individual and this should be informed and
freely given.
The Information Commissioners Office Data Sharing Code of Practice states: “There
must therefore be some form of active communication where the individual
knowingly indicates consent.”
If organisations are going to rely on consent as the condition for sharing, the
individual must know what data sharing they are consenting to and understand the
implications for them. They must also have control over whether or not the data
sharing takes place.
Many electronic health & social care systems cannot be partitioned in a way that will
meet the requirements of the act and allow access to limited data sets to meet the
objectives set out.
Example:
Social work staff based in a hospital require access to demographic information and
details of professionals who have been providing services so they can notify the
appropriate agencies.
Access should be limited to what they need to achieve their objective but many
systems can only give much broader access (in some cases including day to day
care management notes across all disciplines).
The issues are: (but not exhaustive)
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Many service users will not have given their informed, explicit consent to staff
from other organisations to having access to their information
Information accessible may exceed what is required to achieve the objectives
No legal framework for the processing of the data and therefore if there is a
breach the Data Controller has no means of redress.
Where there is no Section 75 agreement or statutory requirement to share
information and the requirements have been met, a robust framework should be put
in place to protect the rights of the individual and data controller.
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A suggested framework might be:
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Completion of the Information Governance Toolkit to level 2
To carry out a privacy impact assessment
Signed Information protocol clearly outlining the justification and purpose of
sharing
A Legally binding Human Resources Deed outlining staff roles and
responsibilities and how breaches will be dealt with or appropriate contract
with relevant data protection and confidentiality clauses
An operational agreement clearly detailing the objectives, who, what, where,
when, how etc
For staff to attend local training
Staff signing a declaration giving their commitment to adhere to all relevant
policies and procedures for both organisations
Access monitoring and staff supervision by both organisations
There is a need to sort out Data controller / data processor relationship and lines of
accountability. Not sure they should both have access. Directors liable under S61 of
DPA and individuals may also be liable if there is a breach of confidence of
Hounslow and Ealing monetary penalty fine.
Q.10 Jan Hoogewerf, Cheshire East
If there is a shared system, with data provided by NHS and social care and an
individual makes a request for access to their records, which include both NHS and
social care assessments, does the request need to be reviewed by both agencies
prior to releasing records? (e.g. redacting third party information). NB Some
assessments and support plans may have input from NHS and social care in a single
assessment document.
Response from Panel:
If there is an Information Sharing Agreement in place between the Health and Social
Care organisations, it may be that this shows an agreement as to whether or not one
or both of the organisations need to give permission to release information under a
subject access request. If an agreement is not in place, it would suggest that both
organisations would need to give permission to share the information before it should
be released.
Some organisations agree that whoever receives the request is responsible for coordinating it for both organisations, however, each organisation would be responsible
for their own file redactions, so the requester would, therefore, only deal with one
organisation.
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Q.11 Jan Hoogewerf, Cheshire East
The PCT are commissioning nurses employed in independent sector nursing homes
to carry out reviews of residents rather than PCT employed nurse assessors. The
nurses will require access to the shared assessment system to record assessments.
The system is web-based and they will not have an N3 connection. The plan is to
require them to comply with the IG Toolkit (voluntary sector chapter). Does this sound
sufficient?
Response from Panel:
It must be remembered that the IG Toolkit is a self-assessment tool and unless the
PCT is carrying out a regular audit of the 3rd party it is difficult to really know if all
aspects of confidentiality levels required are being reached. It would be beneficial to
consider the following in order to strengthen assurance:
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Ensure IG Training for these assessors is in place.
It has been clearly identified who owns the data. So, who is the controller and
who is the processor?
Who would be responsible for dealing with a subject access request?
Is the web based system secure and where is the data being stored?
Who else, other than the nurse assessors have access to this confidential
information?
Web portal needs to be secure so 3 factor authentication of user i.e. same level as
banks. Need to provide information to patients to explain. What information will they
access or is it a case of undertaking the assessment and submitting the record but
not continuing to care or assess in future? Also need secure storage on local system
assuming it will be kept in the nursing home too.
Q.12 Jan Hoogewerf, Cheshire East
On the citizen portal, we are intending to provide individuals with access to their
records on request. To authenticate they will need to set up a user name and
password, where the password needs to be strong (e.g. mix
cases/numbers/characters). Is this likely to be sufficient? (The paper to NIGB from
CAF Programme talked about on-screen characters too to avoid hacking).
Response from Panel:
It is thought that the requirement for health records (not demographic data only) was
meant to be three factor authentication. We think the Cabinet Office stated that
ContactPoint should be two factor i.e. user name and password would suffice.
There is a need to be sure that the person is who they say they are, so for
Healthspace there was a robust registration process (proof of ID and where lives)
and then intended to be user name, password and something else, such as a card
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with numbers on and the person was asked for the letter or number in Row C column
2 type approach; i.e. it was similar to logging into your bank.
For access to the basic portal (unclear at this stage what is intended with the CAF
portal), it may be that two factor authentication would be enough, but if it includes
sensitive personal data then a third factor authentication requirement should be
added.
Should the CAF portal work include sensitive personal data and two factor
authentication is being considered it is recommended NIGB be approached for
advice/comments from the Board.
Q.13 Saq Yasin, Southampton
What is the position where a client gives permission to share, we share information
with a third party and then the permission to share is subsequently rescinded? Do we
have to ask the third party to delete the information? Or is it case of what's done is
done. . . .”
Response from Panel:
Consent should not be retrospective as what has been shared has to remain that
way, decisions may have been taken on the information provided and available at
the time, this needs to be kept as an audit trail of how decisions are reached and
agreed upon. However there might be grounds to ask for information held to be
deleted in some circumstances on a case by case basis.
Carl closed the conference by thanking the panel and the attendees for joining the
call, the discussions had been both in-depth and helpful.
Jan Boucher offered the opportunity for people to email any issues to her or to attend
any of the IG Working Group meetings to discuss things further.
The NIGB are unable to offer a formal response immediately to the questions but it is
their intention to add these questions to their website as Frequently Asked
Questions, as all IG leads can then view them. Chris Hardie will advise when this
happens.
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Attendees (Appendix A)
Panel Members (Bold)
Adam Maddison
Corelogic
Alison Reeve
CAF Team
Beverly Carter
NHS Portsmouth
Carl Evans
Chair
Cheryl Martin
IoW
Chris Hardie
NIGB
Helen Bailey
Stockport
James Leeming
Graphnet
Jan Boucher
Portsmouth CC
Justin Sanders
Liquidlogic
Justin Thorne
IoW
Keith Tadd
Warwickshire
Kevin Cross
Rochdale
Linda Chan
Southampton City Council
Mary Riches
CAF Team
Pat Huston
Stockport
Paul McMahon
Southampton City University Hospitals Trust
Pete Thompson
OLM
Richard Allen
CAF Team/Wiltshire PCT
Robin Ingram
OLM
Robin Murray-Neill CAF Team
Roger Liptrot
Rochdale
Stephen Godfrey
Hampshire
Sue Cooper
LPFIT
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