NHS Digital Data Release Register - reformatted

Isle of Man Department of Health & Social Care projects

12 data files in total were disseminated unsafely (information about files used safely is missing for TRE/"system access" projects).


DSfC - Isle of Man Department of Health and Social Care - Comm — DARS-NIC-173508-F4X6P

Type of data: information not disclosed for TRE projects

Opt outs honoured: No - data flow is not identifiable, Anonymised - ICO Code Compliant (Does not include the flow of confidential data)

Legal basis: Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 – s261(2)(b)(ii)

Purposes: No, Yes (Agency/Public Body)

Sensitive: Sensitive

When:DSA runs 2019-02-01 — 2020-01-31 2020.02 — 2021.05.

Access method: Frequent Adhoc Flow, One-Off

Data-controller type: ISLE OF MAN DEPARTMENT OF HEALTH & SOCIAL CARE

Sublicensing allowed: No

Datasets:

  1. SUS for Commissioners

Objectives:

Commissioning
Currently patients on the Isle of Man that require treatment from services not available on the Isle of Man travel to England to receive treatment. The Isle of Man Department of Health and Social Care wish to understand the rate of patients being sent to the mainland to assist in understanding what services require commissioning locally.

To use pseudonymised data to provide intelligence to support the commissioning of health services. The data (containing both clinical and financial information) is analysed so that health care provision can be planned to support the needs of the population within Isle of Man area.

The Isle of Man Department of Health and Social Care commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.

The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:
- Secondary Uses Service (SUS)
The pseudonymised data is required to for the following purposes:
 Population health management:
• Understanding the interdependency of care services
• Targeting care more effectively
• Using value as the redesign principle
 Data Quality and Validation – allowing data quality checks on the submitted data
 Thoroughly investigating the needs of the population, to ensure the right services are available for individuals when and where they need them
 Understanding cohorts of residents who are at risk of becoming users of some of the more expensive services, to better understand and manage those needs
 Monitoring population health and care interactions to understand where people may slip through the net, or where the provision of care may be being duplicated
 Modelling activity across all data sets to understand how services interact with each other, and to understand how changes in one service may affect flows through another
 Service redesign
 Health Needs Assessment – identification of underlying disease prevalence within the local population
 Patient stratification and predictive modelling - to identify specific patients at risk of requiring hospital admission and other avoidable factors such as risk of falls, computed using algorithms executed against linked de-identified data, and identification of future service delivery models

The pseudonymised data is required to ensure that analysis of health care provision can be completed to support the needs of the health profile of the population within the Isle of Man area based on the full analysis of multiple pseudonymised datasets.
Processing for commissioning will be conducted by Midlands and Lancashire Commissioning Support Unit.

The Isle of Man is a crown-dependency but is not part of the UK and not a part of the EU or EEA. Therefore, for the Isle of Man to receive data an Adequacy Decision must be made.
The European Commission has the power to determine, on the basis of article 45 of Regulation (EU) 2016/679 whether a country outside the EU offers an adequate level of data protection, whether by its domestic legislation or the international commitments it has entered into.

The European Commission has recognised the Isle of Man as providing adequate protection.

Yielded Benefits:

1.Improved health intelligence 2.Improved support analysis of JSNA for specific disease types 3.Improved analysis on provider performance

Expected Benefits:

Commissioning
1. Supporting Quality Innovation Productivity and Prevention (QIPP) to review demand management, integrated care and pathways.
a. Analysis to support full business cases.
b. Develop business models.
c. Monitor In year projects.
2. Supporting Joint Strategic Needs Assessment (JSNA) for specific disease types.
3. Health economic modelling using:
a. Analysis on provider performance against 18 weeks wait targets.
b. Learning from and predicting likely patient pathways for certain conditions, in order to influence early interventions and other treatments for patients.
c. Analysis of outcome measures for differential treatments, accounting for the full patient pathway.
d. Analysis to understand emergency care and linking A&E and Emergency Urgent Care Flows (EUCC).
4. Commissioning cycle support for grouping and re-costing previous activity.
5. Enables monitoring of:
a. Isle of Man Department of Health and Social Care outcome indicators.
b. Financial and Non-financial validation of activity.
c. Successful delivery of integrated care within the Isle of Man Department of Health and Social Care.
d. Checking frequent or multiple attendances to improve early intervention and avoid admissions.
e. Case management.
f. Care service planning.
g. Commissioning and performance management.
h. List size verification by GP practices.
i. Understanding the care of patients in nursing homes.
6. Feedback to NHS service providers on data quality at an aggregate and individual record level – only on data initially provided by the service providers.
7. Improved planning by better understanding patient flows through the healthcare system, thus allowing commissioners to design appropriate pathways to improve patient flow and allowing commissioners to identify priorities and identify plans to address these.
8. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services and early intervention of appropriate care.
9. Improved access to services by identifying which services may be in demand but have poor access, and from this identify areas where improvement is required.
10. Better understanding of the health of and the variations in health outcomes within the population to help understand local population characteristics.
11. Better understanding of contract requirements, contract execution, and required services for management of existing contracts, and to assist with identification and planning of future contracts
12. Insights into patient outcomes, and identification of the possible efficacy of outcomes-based contracting opportunities.
13. Repatriation of patients – ensuring that patients receive the most appropriate service on island enhancing the patient experience.
14. Predicative modelling to reduce IOM residents receiving off island care to reduce UK NHS patient waiting lists, benefit to IOM and UK citizens.

The Isle of Man Department of Health and Social Care work with the NHS through cross border arrangements and commissioning of certain services in England that are not available in the Isle of Man. The data will support the analysis of provision and effective commissioning of services in both the Isle of Man and England.

Outputs:

Commissioning
The running of the data through the Midlands and Lancashire Commissioning Support Unit standard tools was one of the major benefits that the Midlands and Lancashire Commissioning Support Unit offered in terms of providing Isle of Man Department of Health and Social Care with the assurance that payments made are valid (public accountability).
Ideally this dataset would be used by the CSU to analyse and monitor the current financial and activity positions
1. Commissioner reporting:
a. Summary by provider view - plan & actuals year to date (YTD).
b. Summary by Patient Outcome Data (POD) view - plan & actuals YTD.
c. Summary by provider view - activity & finance variance by POD.
d. Planned care by provider view - activity & finance plan & actuals YTD.
e. Planned care by POD view - activity plan & actuals YTD.
f. Provider reporting.
g. Delayed discharges.
h. Quality & performance referral to treatment reporting.
2. Readmissions analysis.
3. Production of aggregate reports for Business Intelligence.
4. Production of project / programme level dashboards.
5. Monitoring of acute / community / mental health quality matrix.
6. Clinical coding reviews / audits.
7. Budget reporting down to individual GP Practice level (IOM GPs only).
8. GP Practice level dashboard reports include high flyers (IOM GPs only).
9. Data Quality and Validation measures allowing data quality checks on the submitted data
10. Contract Management and Modelling
11. Patient Stratification, such as:
o Patients at highest risk of admission
o Most expensive patients (top 15%)
o Frail and elderly
o Patients that are currently in hospital
o Patients with most referrals to secondary care
o Patients with most emergency activity
o Patients with most expensive prescriptions
o Patients recently moving from one care setting to another
i. Discharged from hospital
ii. Discharged from community

Processing:

Data must only be used for the purposes stipulated within this Data Sharing Agreement. Any additional disclosure / publication will require further approval from NHS Digital.
 
Data Processors must only act upon specific instructions from the Data Controller.
 
Data can only be stored at the addresses listed under storage addresses.
 
All access to data is managed under Role-Based Access Controls. Users can only access data authorised by their role and the tasks that they are required to undertake.
 
Patient level data will not be linked other than as specifically detailed within this Data Sharing Agreement. Data released will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement.
 
NHS Digital reminds all organisations party to this agreement of the need to comply with the Data Sharing Framework Contract requirements, including those regarding the use (and purposes of that use) by “Personnel” (as defined within the Data Sharing Framework Contract ie: employees, agents and contractors of the Data Recipient who may have access to that data).

The users on the Isle of Man are limited to those public organisations that are legally part of the Isle of Man Government Department of Health and Social Care.

ONWARD SHARING:
Patient level data will not be shared outside of the the Isle of Man Department of Health and Social Care unless it is for the purpose of Direct Care, where it may be shared only with those health professionals who have a legitimate relationship with the patient and a legitimate reason to access the data.

Aggregated reports only with small number suppression can be shared externally as set out within NHS Digital guidance applicable to each data set.

Segregation
Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.
 
Where the Data Processor and/or the Data Controller hold identifiable data with opt outs applied and identifiable data with opt outs not applied, the data will be held separately so data cannot be linked.

All access to data is audited

DATA MINIMISATION:
Data Minimisation in relation to the data sets listed within the application are listed below. This also includes the purpose on which they would be applied -

For the purpose of Commissioning:
• The Data Controller and any Data Processor will only have access to records of patients of residence and registration within the Isle of Man.

• Data will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement. The data to be released from NHS Digital will not be national data, but only that data relating patients who are resident in the Isle of Man and who have received treatment in England.

Microsoft UK provide Cloud Services for NHS Midlands and Lancashire Commissioning Support Unit and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the Agreement. This includes granting of access to the database[s] containing the data.

Lima Networks Ltd supply IT infrastructure for NHS Midlands and Lancashire Commissioning Support Unit and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Government Technology Services a department of the Isle of Man Cabinet office supply IT infrastructure for the Department of Health and Social Care and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Netcetera and Manx Telecom do not access data held under this agreement as they only supply the building. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Commissioning
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS
Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
Data Processor 1 – Midlands and Lancashire Commissioning Support Unit
1) Pseudonymised SUS only is securely transferred from the DSCRO to Midlands and Lancashire Commissioning Support Unit.
2) Midlands and Lancashire Commissioning Support Unit add derived fields, link data and provide analysis to:
o See patient journeys for pathways or service design, re-design and de-commissioning
o Check recorded activity against contracts or invoices and facilitate discussions with providers.
o Undertake population health management
o Undertake data quality and validation checks
o Thoroughly investigate the needs of the population
o Understand cohorts of residents who are at risk
o Conduct Health Needs Assessments
3) Midlands and Lancashire Commissioning Support Unit then pass the processed, pseudonymised data to Isle of Man Department of Health and Social Care.
4) Aggregation of required data for Isle of Man Department of Health and Social Care management use will be completed by Midlands and Lancashire Commissioning Support Unit as instructed by Isle of Man Department of Health and Social Care
5) Patient level data will not be shared outside of Isle of Man Department of Health and Social Care and will only be shared within Isle of Man Department of Health and Social Care on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared.