NHS Digital Data Release Register - reformatted

NHS Cornwall And The Isles Of Scilly Icb - 11n projects

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


DSfC - NHS Kernow CCG - IV, RS, Comm — DARS-NIC-49735-Q6G7J

Type of data: information not disclosed for TRE projects

Opt outs honoured: No - data flow is not identifiable, Yes - patient objections upheld, Anonymised - ICO Code Compliant, Identifiable (Section 251, Section 251 NHS Act 2006, Mixture of confidential data flow(s) with support under section 251 NHS Act 2006 and non-confidential data flow(s))

Legal basis: Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), National Health Service Act 2006 - s251 - 'Control of patient information'. , Health and Social Care Act 2012 – s261(7), Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 – s261(7); National Health Service Act 2006 - s251 - 'Control of patient information'., Health and Social Care Act 2012 – s261(2)(b)(ii)

Purposes: No (Clinical Commissioning Group (CCG), Sub ICB Location)

Sensitive: Sensitive, and Non Sensitive

When:DSA runs 2019-10-01 — 2022-09-30 2018.06 — 2021.05.

Access method: Frequent adhoc flow, Frequent Adhoc Flow, One-Off

Data-controller type: NHS KERNOW CCG, NHS CORNWALL AND THE ISLES OF SCILLY ICB - 11N

Sublicensing allowed: No

Datasets:

  1. Acute-Local Provider Flows
  2. Ambulance-Local Provider Flows
  3. Children and Young People Health
  4. Community Services Data Set
  5. Community-Local Provider Flows
  6. Demand for Service-Local Provider Flows
  7. Diagnostic Imaging Dataset
  8. Diagnostic Services-Local Provider Flows
  9. Emergency Care-Local Provider Flows
  10. Experience, Quality and Outcomes-Local Provider Flows
  11. Improving Access to Psychological Therapies Data Set
  12. Maternity Services Data Set
  13. Mental Health and Learning Disabilities Data Set
  14. Mental Health Minimum Data Set
  15. Mental Health Services Data Set
  16. Mental Health-Local Provider Flows
  17. National Cancer Waiting Times Monitoring DataSet (CWT)
  18. Other Not Elsewhere Classified (NEC)-Local Provider Flows
  19. Population Data-Local Provider Flows
  20. Primary Care Services-Local Provider Flows
  21. Public Health and Screening Services-Local Provider Flows
  22. SUS for Commissioners
  23. Civil Registration - Births
  24. Civil Registration - Deaths
  25. National Diabetes Audit
  26. Patient Reported Outcome Measures
  27. National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
  28. Improving Access to Psychological Therapies Data Set_v1.5
  29. Civil Registrations of Death
  30. Community Services Data Set (CSDS)
  31. Diagnostic Imaging Data Set (DID)
  32. Improving Access to Psychological Therapies (IAPT) v1.5
  33. Mental Health and Learning Disabilities Data Set (MHLDDS)
  34. Mental Health Minimum Data Set (MHMDS)
  35. Mental Health Services Data Set (MHSDS)
  36. Patient Reported Outcome Measures (PROMs)

Objectives:

Invoice Validation

Invoice validation is part of a process by which providers of care or services get paid for the work they do.
Invoices are submitted to the Clinical Commissioning Group (CCG) so they are able to ensure that the activity claimed for each patient is their responsibility. This is done by processing and analysing Secondary User Services (SUS) data, which is received into a secure Controlled Environment for Finance (CEfF). The SUS data is identifiable at the level of NHS number. The NHS number is only used to confirm the accuracy of backing-data sets and will not be used further.

Invoice Validation with be conducted by the CCG.
The CCG are advised by the CEfF whether payment for invoices can be made or not.


Risk Stratification

Risk stratification is a tool for identifying and predicting which patients are at high risk or are likely to be at high risk and prioritising the management of their care in order to prevent worse outcomes.
To conduct risk stratification Secondary User Services (SUS) data, identifiable at the level of NHS number is linked with Primary Care data (from GPs) and an algorithm is applied to produce risk scores. Risk Stratification provides a forecast of future demand by identifying high risk patients. Commissioners can then prepare plans for patients who may require high levels of care. Risk Stratification also enables General Practitioners (GPs) to better target intervention in Primary Care.

Risk Stratification will be conducted by the CCG


Commissioning

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 the CCG area.
The CCGs 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)
- Local Provider Flows
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
- Mental Health Minimum Data Set (MHMDS)
- Mental Health Learning Disability Data Set (MHLDDS)
- Mental Health Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- Diagnostic Imaging Data Set (DIDS)
- Community Services Data Set (CSDS)
- National Cancer Waiting Times (CWT)

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
• Ensuring we do what we should
§ 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 CCG area based on the full analysis of multiple pseudonymised datasets.
Processing for commissioning will be conducted by the CCG.

Yielded Benefits:

Expected Benefits:


Invoice Validation
1. Financial validation of activity
2. CCG Budget control
3. Commissioning and performance management
4. Meeting commissioning objectives without compromising patient confidentiality
5. The avoidance of misappropriation of public funds to ensure the ongoing delivery of patient care

Risk Stratification
Risk stratification promotes improved case management in primary care and will lead to the following benefits being realised:
1. 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.
2. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services thus allowing early intervention.
3. 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.
4. Supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework by allowing for more targeted intervention in primary care.
5. Better understanding of local population characteristics through analysis of their health and healthcare outcomes
All of the above lead to improved patient experience through more effective commissioning of services.

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. CCG outcome indicators.
b. Financial and Non-financial validation of activity.
c. Successful delivery of integrated care within the CCG.
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. Potentially reduced premature mortality by more targeted intervention in primary care, which supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework.
11. Better understanding of the health of and the variations in health outcomes within the population to help understand local population characteristics.
12. 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
13. Insights into patient outcomes, and identification of the possible efficacy of outcomes-based contracting opportunities.

Outputs:

Invoice Validation
1. Addressing poor data quality issues
2. Production of reports for business intelligence
3. Budget reporting
4. Validation of invoices for non-contracted events


Risk Stratification
1. As part of the risk stratification processing activity detailed above, GPs have access to the risk stratification tool which highlights patients for whom the GP is responsible and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
2. Output from the risk stratification tool will provide aggregate reporting of number and percentage of population found to be at risk.
3. Record level output will be available for commissioners (of the CCG), pseudonymised at patient level.
4. GP Practices will be able to view the risk scores for individual patients with the ability to display the underlying SUS data for the individual patients when it is required for direct care purposes by someone who has a legitimate relationship with the patient.
5. The CCG will be able to target specific patient groups and enable clinicians with the duty of care for the patient to offer appropriate interventions. The CCG will also be able to:
o Stratify populations based on: disease profiles; conditions currently being treated; current service use; pharmacy use and risk of future overall cost
o Plan work for commissioning services and contracts
o Set up capitated budgets
o Identify health determinants of risk of admission to hospital, or other adverse care outcomes.


Commissioning
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. Statutory returns.
h. Statutory returns - monthly activity return.
i. Statutory returns - quarterly activity return.
j. Delayed discharges.
k. Quality & performance referral to treatment reporting.
2. Readmissions analysis.
3. Production of aggregate reports for CCG 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.
8. GP Practice level dashboard reports include high flyers.
9. Comparators of CCG performance with similar CCGs as set out by a specific range of care quality and performance measures detailed activity and cost reports
10. Data Quality and Validation measures allowing data quality checks on the submitted data
11. Contract Management and Modelling
12. 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 as stipulated within this Data Sharing Agreement.

Data Processors must only act upon specific instructions from the Data Controller.

Data can only be stored at the addresses listed under storage addresses.

The Data Controller and any Data Processor will only have access to records of patients of residence and registration within the CCG.

Patient level data will not be shared outside of the CCG 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.

CCGs should work with general practices within their CCG to help them fulfil data controller responsibilities regarding flow of identifiable data into risk stratification tools.

No patient level data will be linked other than as specifically detailed within this agreement. 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 to the specific locality of interest of the applicant.

The DSCRO (part of NHS Digital) will apply Type 2 objections before any identifiable data leaves the DSCRO only for the purpose of Risk Stratification.

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)

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.
All access to data is audited

Data for the purpose of Invoice Validation is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CEfF staff are able to access data in the CEfF and only CEfF staff operate the invoice validation process within the CEfF. Data flows directly in to the CEfF from the DSCRO and from the providers – it does not flow through any other processors.


Invoice Validation
1. SUS Data is obtained from the SUS Repository by the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO pushes a one-way data flow of SUS data into the Controlled Environment for Finance (CEfF) located in the CCG.
3. The CEfF conduct the following processing activities for invoice validation purposes:
a. Checking the individual is registered to the Clinical Commissioning Group (CCG) by using the derived commissioner field in SUS and associated with an invoice from the SUS data flow to validate the corresponding record in the backing data flow
b. Once the backing information is received, this will be checked against national NHS and local commissioning policies as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:
i. In line with Payment by Results tariffs
ii. In relation to a patient registered with the CCG GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance. 
4. The CCG are notified by the CEfF that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved

Risk Stratification
1. Identifiable SUS data is obtained from the SUS Repository to the Data Services for Commissioners Regional Office (DSCRO).
2. Data quality management and standardisation of data is completed by the DSCRO and the data identifiable at the level of NHS number is transferred securely to the CCG, who hold the SUS data within the secure Data Centre on N3.
3. Identifiable GP Data is securely sent from the GP system to the CCG.
4. SUS data is linked to GP data in the risk stratification tool by the data processor.
5. As part of the risk stratification processing activity, GPs have access to the risk stratification tool within the data processor, which highlights patients with whom the GP has a legitimate relationship and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
6. Once the CCG has completed the processing, access is available through the online system via a secure N3 connection to access the data pseudonymised at patient level.


Commissioning
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS
2. Local Provider Flows (received directly from providers)
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
3. Mental Health Minimum Data Set (MHMDS)
4. Mental Health Learning Disability Data Set (MHLDDS)
5. Mental Health Services Data Set (MHSDS)
6. Maternity Services Data Set (MSDS)
7. Improving Access to Psychological Therapy (IAPT)
8. Child and Young People Health Service (CYPHS)
9. Community Services Data Set (CSDS)
10. Diagnostic Imaging Data Set (DIDS)
11. National Cancer Waiting Times Monitoring Data Set (CWT)

Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
Data Processor 1 – The CCG
1) Pseudonymised SUS+, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young People’s Health data (CYPHS), Community Services Data Set (CSDS), Diagnostic Imaging data (DIDS) and National Cancer Waiting Times Monitoring Data Set (CWT) only is securely transferred from the DSCRO to the CCG.
2) The CCG 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) Allowed linkage is between the data sets contained within point 1.
4) Aggregation of required data for CCG management use will be completed by the CCG.
5) Patient level data will not be shared outside of the CCG and will only be shared within the CCG 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.


GDPPR COVID-19 – CCG - Pseudo — DARS-NIC-384661-Z9H3W

Type of data: information not disclosed for TRE projects

Opt outs honoured: No - Statutory exemption to flow confidential data without consent, Anonymised - ICO Code Compliant (Statutory exemption to flow confidential data without consent)

Legal basis: CV19: Regulation 3 (4) of the Health Service (Control of Patient Information) Regulations 2002, CV19: Regulation 3 (4) of the Health Service (Control of Patient Information) Regulations 2002; Health and Social Care Act 2012 - s261(5)(d)

Purposes: No (Clinical Commissioning Group (CCG), Sub ICB Location)

Sensitive: Sensitive

When:DSA runs 2020-09-22 — 2021-03-31 2021.01 — 2021.05.

Access method: One-Off, Frequent Adhoc Flow

Data-controller type: NHS KERNOW CCG, NHS CORNWALL AND THE ISLES OF SCILLY ICB - 11N

Sublicensing allowed: No

Datasets:

  1. GPES Data for Pandemic Planning and Research (COVID-19)
  2. COVID-19 Ethnic Category Data Set
  3. COVID-19 Vaccination Status
  4. COVID-19 General Practice Extraction Service (GPES) Data for Pandemic Planning and Research (GDPPR)

Objectives:

NHS Digital has been provided with the necessary powers to support the Secretary of State’s response to COVID-19 under the COVID-19 Public Health Directions 2020 (COVID-19 Directions) and support various COVID-19 purposes, the data shared under this agreement can be used for these specified purposes except where they would require the reidentification of individuals.

GPES data for pandemic planning and research (GDPPR COVID 19)
To support the response to the outbreak, NHS Digital has been legally directed to collect and analyse healthcare information about patients from their GP record for the duration of the COVID-19 emergency period under the COVID-19 Directions.
The data which NHS Digital has collected and is providing under this agreement includes coded health data, which is held in a patient’s GP record, such as details of:
• diagnoses and findings
• medications and other prescribed items
• investigations, tests and results
• treatments and outcomes
• vaccinations and immunisations

Details of any sensitive SNOMED codes included in the GDPPR data set can be found in the Reference Data and GDPPR COVID 19 user guides hosted on the NHS Digital website. SNOMED codes are included in GDPPR data.
There are no free text record entries in the data.

The Controller will use the pseudonymised GDPPR COVID 19 data to provide intelligence to support their local response to the COVID-19 emergency. The data is analysed so that health care provision can be planned to support the needs of the population within the CCG area for the COVID-19 purposes.

Such uses of the data include but are not limited to:

• Analysis of missed appointments - Analysis of local missed/delayed referrals due to the COVID-19 crisis to estimate the potential impact and to estimate when ‘normal’ health and care services may resume, linked to Paragraph 2.2.3 of the COVID-19 Directions.

• Patient risk stratification and predictive modelling - to highlight patients at risk of requiring hospital admission due to COVID-19, computed using algorithms executed against linked de-identified data, and identification of future service delivery models linked to Paragraph 2.2.2 of the COVID-19 Directions. As with all risk stratification, this would lead to the identification of the characteristics of a cohort that could subsequently, and separately, be used to identify individuals for intervention. However the identification of individuals will not be done as part of this data sharing agreement, and the data shared under this agreement will not be reidentified.

• Resource Allocation - In order to assess system wide impact of COVID-19, the GDPPR COVID 19 data will allow reallocation of resources to the worst hit localities using their expertise in scenario planning, clinical impact and assessment of workforce needs, linked to Paragraph 2.2.4 of the COVID-19 Directions:

The data may only be linked by the Data Controller or their respective Data Processor, to other pseudonymised datasets which it holds under a current data sharing agreement only where such data is provided for the purposes of general commissioning by NHS Digital. The Health Service Control of Patient Information Regulations (COPI) will also apply to any data linked to the GDPPR data.
The linked data may only be used for purposes stipulated within this agreement and may only be held and used whilst both data sharing agreements are live and in date. Using the linked data for any other purposes, including non-COVID-19 purposes would be considered a breach of this agreement. Reidentification of individuals is not permitted under this DSA.

LEGAL BASIS FOR PROCESSING DATA:
Legal Basis for NHS Digital to Disseminate the Data:
NHS Digital is able to disseminate data with the Recipients for the agreed purposes under a notice issued to NHS Digital by the Secretary of State for Health and Social Care under Regulation 3(4) of the Health Service Control of Patient Information Regulations (COPI) dated 17 March 2020 (the NHSD COPI Notice).
The Recipients are health organisations covered by Regulation 3(3) of COPI and the agreed purposes (paragraphs 2.2.2-2.2.4 of the COVID-19 Directions, as stated below in section 5a) for which the disseminated data is being shared are covered by Regulation 3(1) of COPI.

Under the Health and Social Care Act, NHS Digital is relying on section 261(5)(d) – necessary or expedient to share the disseminated data with the Recipients for the agreed purposes.


Legal Basis for Processing:
The Recipients are able to receive and process the disseminated data under a notice issued to the Recipients by the Secretary of State for Health and Social Care under Regulation 3(4) of COPI dated 20th March (the Recipient COPI Notice section 2).

The Secretary of State has issued notices under the Health Service Control of Patient Information Regulations 2002 requiring the following organisations to process information:

Health organisations

“Health Organisations” defined below under Regulation 3(3) of COPI includes CCGs for the reasons explained below. These are clinically led statutory NHS bodies responsible for the planning and commissioning of health care services for their local area

The Secretary of State for Health and Social Care has issued NHS Digital with a Notice under Regulation 3(4) of the National Health Service (Control of Patient Information Regulations) 2002 (COPI) to require NHS Digital to share confidential patient information with organisations permitted to process confidential information under Regulation 3(3) of COPI. These include:

• persons employed or engaged for the purposes of the health service

Under Section 26 of the Health and Social Care Act 2012, CCG’s have a duty to provide and manage health services for the population.

Regulation 7 of COPI includes certain limitations. The request has considered these limitations, considering data minimisation, access controls and technical and organisational measures.

Under GDPR, the Recipients can rely on Article 6(1)(c) – Legal Obligation to receive and process the Disclosed Data from NHS Digital for the Agreed Purposes under the Recipient COPI Notice. As this is health information and therefore special category personal data the Recipients can also rely on Article 9(2)(h) – preventative or occupational medicine and para 6 of Schedule 1 DPA – statutory purpose.

Expected Benefits:

• Manage demand and capacity
• Reallocation of resources
• Bring in additional workforce support
• Assists commissioners to make better decisions to support patients
• Identifying COVID-19 trends and risks to public health
• Enables CCGs to provide guidance and develop policies to respond to the outbreak
• Controlling and helping to prevent the spread of the virus

Outputs:

• Operational planning to predict likely demand on primary, community and acute service for vulnerable patients due to the impact of COVID-19
• Analysis of resource allocation
• Investigating and monitoring the effects of COVID-19
• Patient Stratification in relation to COVID-19, such as:
o Patients at highest risk of admission
o Frail and elderly
o Patients that are currently in hospital
o Patients with prescriptions related to COVID-19
o Patients recently Discharged from hospital
For avoidance of doubt these are pseudonymised patient cohorts, not identifiable.

Processing:

PROCESSING CONDITIONS:
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.

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.

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 i.e.: employees, agents and contractors of the Data Recipient who may have access to that data).

The Recipients will take all required security measures to protect the disseminated data and they will not generate copies of their cuts of the disseminated data unless this is strictly necessary. Where this is necessary, the Recipients will keep a log of all copies of the disseminated data and who is controlling them and ensure these are updated and destroyed securely.

Onward sharing of patient level data is not permitted under this agreement. Only aggregated reports with small number suppression can be shared externally.

The data disseminated will only be used for COVID-19 GDPPR purposes as described in this DSA, any other purpose is excluded.

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.

AUDIT
All access to data is auditable by NHS Digital in accordance with the Data Sharing Framework Contract and NHS Digital terms.
Under the Local Audit and Accountability Act 2014, section 35, Secretary of State has power to audit all data that has flowed, including under COPI.

DATA MINIMISATION:
Data Minimisation in relation to the data sets listed within the application are listed below:

• Patients who are normally registered and/or resident within the CCG region (including historical activity where the patient was previously registered or resident in another commissioner area).
and/or
• Patients treated by a provider where the CCG is the host/co-ordinating commissioner and/or has the primary responsibility for the provider services in the local health economy.
and/or
• Activity identified by the provider and recorded as such within national systems (such as SUS+) as for the attention of the CCG.

The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
- GDPPR COVID 19 Data
Pseudonymisation is completed within the DSCRO and is then disseminated as follows:
1. Pseudonymised GDPPR COVID 19 data is securely transferred from the DSCRO to the Data Controller / Processor
2. Aggregation of required data will be completed by the Controller (or the Processor as instructed by the Controller).
3. Patient level data may not be shared by the Controller (or any of its processors).


DSfC NHS Kernow CCG RS — DARS-NIC-226613-D8S2N

Type of data: information not disclosed for TRE projects

Opt outs honoured: Yes - patient objections upheld, Identifiable (Section 251, Section 251 NHS Act 2006)

Legal basis: National Health Service Act 2006 - s251 - 'Control of patient information'. , Health and Social Care Act 2012 – s261(7); National Health Service Act 2006 - s251 - 'Control of patient information'.

Purposes: No (Clinical Commissioning Group (CCG), Sub ICB Location)

Sensitive: Sensitive

When:DSA runs 2019-02-06 — 2022-02-05 2018.10 — 2021.05.

Access method: Frequent Adhoc Flow, One-Off

Data-controller type: NHS KERNOW CCG, NHS CORNWALL AND THE ISLES OF SCILLY ICB - 11N

Sublicensing allowed: No

Datasets:

  1. SUS for Commissioners

Objectives:

Risk stratification is a tool for identifying and predicting which patients are at high risk or are likely to be at high risk and prioritising the management of their care in order to prevent worse outcomes.
To conduct risk stratification Secondary User Services (SUS+) data, identifiable at the level of NHS number is linked with Primary Care data (from GPs) and an algorithm is applied to produce risk scores. Risk Stratification provides focus for future demands by enabling commissioners to prepare plans for patients. Commissioners can then prepare plans for patients who may require high levels of care. Risk Stratification also enables General Practitioners (GPs) to better target intervention in Primary Care.

Risk Stratification will be conducted by Prescribing Services Limited

Yielded Benefits:

Expected Benefits:

Risk stratification promotes improved case management in primary care and will lead to the following benefits being
realised:
1. 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.
2. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services thus allowing early
intervention.
3. 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.
4. Supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework by allowing for more targeted intervention in primary care.
5. Better understanding of local population characteristics through analysis of their health and healthcare outcomes.
All of the above lead to improved patient experience through more effective commissioning of services.

Outputs:

1. As part of the risk stratification processing activity detailed above, GPs have access to the risk stratification tool which highlights patients for whom the GP is responsible and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
2. Output from the risk stratification tool will provide aggregate reporting of number and percentage of population found to be at risk.
3. Record level output will be available for commissioners (of the CCG), pseudonymised at patient level.
4. GP Practices will be able to view the risk scores for individual patients with the ability to display the underlying SUS+ data for the individual patients when it is required for direct care purposes by someone who has a legitimate relationship with the patient.
5. The CCG will be able to target specific patient groups and enable clinicians with the duty of care for the patient to offer appropriate interventions. The CCG will also be able to:
o Stratify populations based on: disease profiles; conditions currently being treated; current service use; pharmacy use and risk of future overall cost
o Plan work for commissioning services and contracts
o Set up capitated budgets
o Identify health determinants of risk of admission to hospital, or other adverse care outcomes.

Processing:

Data must only be used as stipulated within this Data Sharing Agreement.

Data Processors must only act upon specific instructions from the Data Controller.

Data can only be stored at the addresses listed under storage addresses.

Patient level data will not be shared outside of the CCG 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.

All access to data is managed under Roles-Based Access Controls

No patient level data will be linked other than as specifically detailed within this agreement. 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 to the specific locality and that data required by the applicant.

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 DSCRO (part of NHS Digital) will apply Type 2 objections before any identifiable data leaves the DSCRO.

CCGs should work with general practices within their CCG to help them fulfil data controller responsibilities regarding flow of identifiable data into risk stratification tools.

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.

All access to data is auditable by NHS Digital.



Data Minimisation in relation to the data sets listed within section 3 are listed below. This also includes the purpose on which they would be applied -
For the purpose of Risk Stratification:
• Patients who are normally registered and/or resident within the commissioner (including historical activity where the patient was previously registered or resident in another commissioner


Risk Stratification
1. Identifiable SUS+ data is obtained from the SUS Repository to the Data Services for Commissioners Regional Office (DSCRO).
2. Data quality management and standardisation of data is completed by the DSCRO and the data identifiable at the level of NHS number is transferred securely to Prescribing Services Ltd, who hold the SUS+ data within the secure Data Centre on N3.
3. Identifiable GP Data is securely sent from the GP system to Prescribing Services Ltd.
4. SUS+ data is linked to GP data in the risk stratification tool by the data processor.
5. As part of the risk stratification processing activity, GPs have access to the risk stratification tool within the data
processor, which highlights patients with whom the GP has a legitimate relationship and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
6. Once Prescribing Services Ltd has completed the processing, the CCG can access the online system via a secure connection to access the data pseudonymised at patient level.