NHS Digital Data Release Register - reformatted

NHS Coventry And Warwickshire CCG projects

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


🚩 NHS Coventry And Warwickshire CCG was sent multiple files from the same dataset, in the same month, both with optouts respected and with optouts ignored. NHS Coventry And Warwickshire CCG may not have compared the two files, but the identifiers are consistent between datasets, and outside of a good TRE NHS Digital can not know what recipients actually do.

DSfC NHS Coventry and Warwickshire CCG - IV, RS & Comm — DARS-NIC-422218-V6L8T

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 (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 - 'Other dissemination of information', 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 2021-04-01 — 2024-03-31 2021.04 — 2021.05.

Access method: One-Off, Frequent Adhoc Flow

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

Sublicensing allowed: No

Datasets:

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

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 the CCG is 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 (data from providers)

The CCG are advised by the appointed CEfF whether payment for invoices can be made or not.

Invoice Validation will be conducted by NHS Arden and Greater East Midlands Commissioning Support Unit and Liaison Financial Services Ltd.

Liaison Financial Services Ltd conduct an independent ad-hoc review on retrospective payments made. Investing resource, skills and experience into deeper reconciliation, this identifies overcharges already paid and recovers savings for the CCG that would otherwise be lost.

RISK STRATIFICATION
Risk stratification is a tool for identifying and predicting which patients are at high risk (of health deterioration and using multiple services) 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 both individual and groups of vulnerable 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 Ltd


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.

This Agreement permits the use of 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 Sustainability Transformation Partnership (STP) area, which includes the following:

- Coventry and Warwickshire NHS Partnership Trust
- Coventry City Council
- George Eliot Hospital NHS Trust
- South Warwickshire NHS Foundation Trust
- University Hospitals Coventry and Warwickshire NHS Trust
- Warwickshire County Council
- NHS Coventry and Warwickshire CCG

Only the CCG will have access to patient level data, the other organisations will only have access to aggregated data in line with NHS Digital small suppression rules.

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)
- Community Services Data Set (CSDS)
- Diagnostic Imaging Data Set (DIDS)
- National Cancer Waiting Times Monitoring Data Set (CWT)
- Civil Registries Data (CRD) (Births)
- Civil Registries Data (CRD) (Deaths)
- National Diabetes Audit (NDA)
- Patient Reported Outcome Measures (PROMs)
- e-Referral Service (eRS)
- Summary Hospital-level Mortality Indicator (SHMI)
- Medicines Dispensed in Primary Care (NHSBSA Data)

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 highlight cohorts of 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
 Demand Management - to improve the care service for patients by predicting the impact on certain care pathways and support the secondary care system in ensuring enough capacity to manage the demand.
 Support measuring the health, mortality or care needs of the total local population.
 Provide intelligence about the safety and effectiveness of medicines.

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 NHS Coventry and Warwickshire CCG, NHS Arden and GEM Commissioning Support Unit, South Warwickshire GP and South Warwickshire NHS Foundation Trust

The CCG wish to include pseudonymised primary care data in the population health management and patient stratification analyses to enable more comprehensive and patient/pathway focused analyses.

Patient data historically sits in silos within various NHS services. Linking datasets including GP data enables commissioners to better understand the effective delivery of health and social care services for the populations they manage and not just for those directly receiving treatment. It supports commissioners to allocate resources as well as providing greater insight into the provision of services and into the health of the population.

Linking primary care and secondary care data supports with understanding a patient’s full journey across their pathway and across the community which can provide opportunities for understanding health needs pre and post treatment across numerous health services, for example, analysis has shown that those able to manage their health conditions (GP data) are less likely to attend Accident and Emergency and less likely to be admitted in an emergency (secondary care data). It can also support with coordinating discharge planning and integration of services as those receiving social care can be a key driver of demand for health and care.

Processing for commissioning, including the pseudo at source processing necessary for patient stratification and population health management will be conducted by NHS Arden and GEM Commissioning Support Unit.

The CCG of the STP programme have planned a number of initiatives and work-streams for local service providers to work together and develop new service models for the future delivery of high quality, efficient and effective services across Coventry and Warwickshire, for example the Out-of-Hospital Programme.

The STP and the CCG now wish to engage the services of additional data processors to better utilise the potential provided through the linking of primary care data and secondary care data (previously approved) particularly for additional support with their population health management and patient stratification programme.

• South Warwickshire GP Federation Ltd (SWGP),
and
• South Warwickshire Foundation NHS Trust (SWFT)

These data processors will each bring their own specific expertise in analysing the pseudonymised datasets SWGP will apply their primary care expertise from experience, knowledge and insight about GP data and SWFT will apply their secondary care expertise from their associated experience, knowledge and insight regarding the hospital and community data. There will be a small team of analysts providing this support within each organisation, so access to data will be restricted, especially with the Provider Trust (SWFT).

The pseudonymised outputs of the analysis will be used by the CCG to support their whole commissioning agenda, for example to support the CCG with work around data quality and service re-design in both primary and secondary care. Pseudonymised outputs will also be used to feed into the interdisciplinary teams of clinical staff that will work across Coventry and Warwickshire. Only the GP Practice where the patient is registered will be able to re-identify patients and only when they need to do so for direct care purposes. GP Practices will make referrals to services as required.

Expected Benefits:

INVOICE VALIDATION
The invoice validation process supports the ongoing delivery of patient care across the NHS and the CCG region by:
1. Ensuring that activity is fully financially validated.
2. Ensuring that service providers are accurately paid for the patients treatment.
3. Enabling services to be planned, commissioned, managed, and subjected to financial control.
4. Enabling commissioners to confirm that they are paying appropriately for treatment of patients for whom they are responsible.
5. Fulfilling commissioners duties to fiscal probity and scrutiny.
6. Ensuring full financial accountability for relevant organisations.
7. Ensuring robust commissioning and performance management.
8. Ensuring commissioning objectives do not compromise patient confidentiality.
9. Ensuring the avoidance of misappropriation of public funds.

Liaison Financial Services Ltd
1. Financial validation of activity
2. CCG Budget control
3. Assurances over the robustness of internal control mechanisms relating to the payment of invoices and/or suggested improvements
4. Identification and recovery of monies which would otherwise be lost
5. Meeting commissioning objectives without compromising patient confidentiality
6. The avoidance of misappropriation of public funds to ensure the ongoing delivery of patient care
7. Benefit delivered 3-9 months from receiving data, depending on number of claims to investigate and resolve


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 and health outcomes 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.
14. Providing greater understanding of the underlying courses and look to commission improved supportive networks, this would be ongoing work which would be continually assessed.
15. Insight to understand the numerous factors that play a role in the outcome for both datasets. The linkage will allow the reporting both prior to, during and after the activity, to provide greater assurance on predictive outcomes and delivery of best practice.
16. Provision of indicators of health problems, and patterns of risk within the commissioning region.
17. Support of benchmarking for evaluating progress in future years.
18. Allow reporting to drive changes and improve the quality of commissioned services and health outcomes for people.
19. Assists commissioners to make better decisions to support patients and drive changes in health care
20. Allows comparisons of providers performance to assist improvement in services – increase the quality
21. Allow analysis of health care provision to 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.
22. To evaluate the impact of new services and innovations (e.g. if commissioners implement a new service or type of procedure with a provider, they can evaluate whether it improves outcomes for patients compared to the previous one).
23. Monitoring of entire population, as a pose to only those that engage with services
24. Enable Commissioners to be able to see early indications of potential practice resilience issues in that an early warning marker can often be a trend of patients re-registering themselves at a neighbouring practice.
25. Monitor the quality and safety of the delivery of healthcare services.
26. Allow focused commissioning support based on factual data rather than assumed and projected sources
27. Understand admissions linked to overprescribing.
28. Add value to the population health management workstream by adding prescribing data into linked dataset for segmentation and stratification.

The CCG want to utilise these 2 additional data processors because of their expertise in primary and secondary care data and the added resource they will provide. Therefore, the level of benefit overall will be much higher.

South Warwickshire GP Ltd
1. Higher level of patient stratification allowing direct care intervention
2. Knowledge sharing and best practices procedures for GP practises
3. Higher utilisation of the data and its tools allowing GP practices to easily identify areas of concern

South Warwickshire NHS Foundation Trust:
1. Greater insight into population and patient stratification using secondary care data
2. Higher level of patient stratification allowing direct care intervention
3. Allow further identification of possible factors relating to patients soon to be at risk, not previously identified

Outputs:

INVOICE VALIDATION
1. The Controlled Environment for Finance (CEfF) will enable the CCG to challenge invoices and raise discrepancies and disputes.
2. Outputs from the CEfF will enable accurate production of budget reports, which will:
a. Assist in addressing poor quality data issues
b. Assist in business intelligence
3. Validation of invoices for non-contracted events where a service delivered to a patient by a provider that does not have a written contract with the patient’s responsible commissioner, but does have a written contract with another NHS commissioner/s.
4. Budget control of the CCG.

Liaison Financial Services Ltd
1. Validation of Continuing Healthcare related invoices and payments
2. Independent Identification of potential overpayments made by the CCG through invoice validation
3. Liaising with providers with a view to recouping these monies
4. Review is completed for the retrospective period from date of contract with Liaison Financial Services back to 01/04/2013.
5. Reviews take 3-9 months depending on number of claims to investigate and resolve
6. Liaison Financial Services would repeat the exercise 2-3 years later
7. CCGs could request reviews to be done more frequently
8. SUS+ would only be requested each time a review was completed, and could be requested at different times as independent reviews

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. 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.

CCGs will be able to:
3. Target specific vulnerable patient groups and enable clinicians with the duty of care for the patient to offer appropriate interventions.
4. Reduce hospital readmissions and targeting clinical interventions to high risk patients.
5. Identify patients at risk of deterioration and providing effective care.
6. Reduce in the difference in the quality of care between those with the best and worst outcomes.
7. Re-design care to reduce admissions.
8. Set up capitated budgets – budgets based on care provided to the specific population.
9. Identify health determinants of risk of admission to hospital, or other adverse care outcomes.
10. Monitor vulnerable groups of patients including but not limited to frailty, COPD, Diabetes, elderly.
11. Health needs assessments – identifying numbers of patients with specific health conditions or combination of conditions.
12. Classify vulnerable groups based on: disease profiles; conditions currently being treated; current service use; pharmacy use and risk of future overall cost.
13. Production of Theographs – a visual timeline of a patients encounters with hospital providers.
14. Analyse based on specific diseases
In addition:
- The risk stratification tool will provide aggregate reporting of number and percentage of population found to be at risk.
- Record level output (pseudonymised) will be available for commissioners (of the CCG), pseudonymised at patient level. Onward sharing of this data is not permitted.

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.
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 High cost activity uses (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
13. Validation for payment approval, ability to validate that claims are not being made after an individual has died, like Oxygen services.
14. Validation of programs implemented to improve patient pathway e.g. High users unable to validate if the process to help patients find the best support are working or did the patient die.
15. Clinical - understand reasons why patients are dying, what additional support services can be put in to support.
16. Understanding where patient are dying e.g. are patients dying at hospitals due to hospices closing due to Local authorities withdrawing support, or is there a problem at a particular trust.
17. Removal of patients from Risk Stratification reports.
18. Re births provide a one stop shop of information, Births are recorded in multiple sources covering hospital and home births, a chance to overlook activity.
19. Manage demand, by understanding the quantity of assessments required CCGs are able to improve the care service for patients by predicting the impact on certain care pathways and ensure the secondary care system has enough capacity to manage the demand.
20. Monitor the timing of key actions relating to referral letters. CCG’s are unable to see the contents of the referral letters.
21. Identify low priority procedures which could be directed to community-based alternatives and as such commission these services and deflect referrals for low priority procedures resulting in a reduction in hospital referrals.
22. Allow Commissioners to better protect or improve the public health of the total local patient population
23. Allow Commissioners to plan, evaluate and monitor health and social care policies, services, or interventions for the total local patient population
24. Allow Commissioners to compare their providers (trusts) mortality outcomes to the national baseline.
25. Investigate mortality outcomes for trusts.
26. Identify medication prescribing trends and their effectiveness.
27. Linking prescribing habits to entry points into the health and social care system
28. Identify, quantify and understand cohorts of patient’s high numbers of different medications (polypharmacy)


South Warwickshire GP Ltd:
Using their knowledge of primary care data, South Warwickshire GP Ltd will be able to provide further analysis of the data, specifically around patient stratification. This will allow more detailed analysis of patients who may be at risk and provide prevention strategies. These reports will be made available to GP Practises for their own patients where they may only re-identify for direct care purposes

South Warwickshire GP Federation Ltd will be able to support practices by identifying these patients (through the pseudonymised route) for practices to re-identify as necessary for direct care and target suitable interventions and care plans and reducing the burden and workload on GP practices. The Federation will in turn have greater familiarity with the tool and its findings and share this knowledge and expertise with their practice population. They will be supporting the Practices with additional knowledge and expertise on getting the most out of data, tools and reporting but also supporting the CCG with expertise and knowledge of primary care data and GP systems and services.

South Warwickshire NHS Foundation Trust:
Using their knowledge of secondary care data, South Warwickshire NHS Foundation Trust give greater insight into population health and patient stratification and provide reports to GP Practises for their own patients where they may only re-identify for direct care purposes.

While the system is usually aware of the top 5% most complex patients, it is the next 15% of the population that the stratification analysis can identify which will provide vital information to multi-disciplinary teams that support GP Practices and the health system as a whole. The teams can then review these patients as directed by the GP Practices which they support to inform future care plans and interventions such as lifestyle management to assist in preventing hospitalisation. SWFT, as data processor on behalf of the CCGs, can fully support this process and work with the GP Practices to prioritise this patient cohort.

Following the COVID-19 pandemic, it will be more important than ever for the CCGs, Practices, SWFT and GP Federation to work collaboratively across the system to use Patient Stratification and Population Health Management techniques to better understand what that population needs during and post COVID-19. The analytical outputs will support in under-pinning the restoration of services and pathways and to help prioritise the needs of the population.

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 DSCRO (part of NHS Digital) will apply National Opt-outs before any identifiable data leaves the DSCRO only for the purpose of Risk Stratification.

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.

The identifier available in the data set is the NHS numbers. Any further identification of the patients will only be completed by the patient’s clinician on their own systems for the purpose of direct care with a legitimate relationship.

ONWARD SHARING:
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.

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 auditable by NHS Digital.

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.

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

For the purpose of Risk Stratification:
• Patients who are normally registered and/or resident within the NHS Coventry and Warwickshire CCG region (including historical activity where the patient was previously registered or resident in another commissioner

For the purpose of Invoice Validation:
• Patients who are resident and/or registered within the CCG region.

This includes data that was previously under a different organisation name but has now merged into this CCG

In addition to the dissemination of Cancer Waiting Times Data via the DSCRO, the CCG is able to access reports held within the CWT system in NHS Digital directly. Access within the CCG is limited to those with a need to process the data for the purposes described in this agreement.

A CCG user will be able to access the provider extracts from the portal for any provider where at least 1 patient for whom they are the registered CCG for that individuals GP practice appears in that setting

Although a CCG user may have access to pseudonymised patient information not related to that CCG, users should only process and analyse data for which they have a legitimate relationship (as described within Data Minimisation).

Microsoft Limited supply Cloud Services for South Warwickshire GP Limited, NHS Arden and GEM CSU and Liaison Financial Services Ltd 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.

Coventry and Warwickshire Partnership NHS Trust supply IT infrastructure 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.

NHS Midlands and Lancashire Commissioning Support Unit and Greater Manchester Shared Services (hosted by Salford Royal NHS Foundation Trust) supply IT infrastructure for Arden and GEM Commissioning Support Unit and are therefore listed as data processors. 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.

Ilkeston Community Hospital (Part of Derbyshire Community Health Services NHS Foundation Trust), Wrightington, Wigan and Leigh NHS Foundation Trust and The Bunker 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.

INVOICE VALIDATION

Arden and GEM CSU
1. Identifiable SUS+ and PDS Data is obtained by the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO pushes a one-way data flow of SUS+ and PDS data into the Controlled Environment for Finance (CEfF) in the Arden and GEM CSU.
3. The CEfF also receive backing data from the provider.
4. Arden and GEM CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Validating that the Clinical Commissioning Group are responsible for payment for the care of the individual by using SUS+ and PDS and/or provider backing flow data.
b. Once the provider 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. are in relation to a patient registered with a CCG GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance. 
5. The CCG are notified that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Arden and GEM CSU CEfF team and the provider, meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.

Liaison Financial Services Ltd
1. Identifiable SUS+ and PDS Data is obtained by the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO pushes a one-way data flow of SUS+ and PDS data into the Controlled Environment for Finance (CEfF) in the Liaison Financial Services Ltd.
3. The CEfF also receive backing data from the provider.
4. Liaison Financial Services Ltd carry out the following processing activities within the CEfF for invoice validation purposes:
a. Validating that the Clinical Commissioning Group are responsible for payment for the care of the individual by using SUS+ and PDS and/or provider backing flow data.
b. Once the provider 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. are in relation to a patient registered with a CCG GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance. 
5. The CCG are notified that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Liaison Financial Services Ltd CEfF team and the provider, meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.

RISK STRATIFICATION
Prescribing Services Ltd
1. Identifiable SUS+ and Mental Health Services Dataset (MHSDS) data is transferred 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 securely hold the SUS+ and MHSDS data.
3. Identifiable GP Data is securely sent from the GP system to Prescribing Services Ltd.
4. SUS+ and MHSDS 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


COMMISSIONING
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS+
2. Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Demand for Service
e. Diagnostic Service
f. Emergency Care
g. Experience, Quality and Outcomes
h. Mental Health
i. Other Not Elsewhere Classified
j. Population Data
k. Primary Care Services
l. 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)
12. Civil Registries Data (CRD) (Births)
13. Civil Registries Data (CRD) (Deaths)
14. National Diabetes Audit (NDA)
15. Patient Reported Outcome Measures (PROMs)
16. e-Referral Service (eRS)
17. Personal Demographics Service (PDS)
18. Summary Hospital-level Mortality Indicator (SHMI)
19. Medicines Dispensed in Primary Care (NHSBSA Data)

Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:

Data Processor 1 – NHS Arden and GEM Commissioning Support Unit
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), National Cancer Waiting Times Monitoring Data Set (CWT), Civil Registries Data (CRD) (Births and Deaths), Patient Reported Outcome Measures (PROMs), National Diabetes Audit (NDA) , e-Referral Service (eRS), Personal Demographics Service (PDS), Summary Hospital-level Mortality Indicator (SHMI) and Medicines Dispensed in Primary Care (NHSBSA Data) Data only is securely transferred from the DSCRO to Arden and GEM Commissioning Support Unit..
2. NHS Arden and Greater East Midlands Commissioning Support Unit receive GP data (as points i-x)
3. Data listed within point 1 is then linked to the pseudonymised GP data and analysis is provided to:
a. See patient journeys for pathways or service design, re-design and de-commissioning.
b. Check recorded activity against contracts or invoices and facilitate discussions with providers.
c. Undertake population health management
d. Undertake data quality and validation checks
e. Thoroughly investigate the needs of the population
f. Understand cohorts of residents who are at risk
g. Conduct Health Needs Assessments
4. NHS Arden and Greater East Midlands Commissioning Support Unit then pass the processed, pseudonymised and linked data to the CCG.
5. Aggregation of required data for CCG management use will be completed by NHS Arden and Greater East Midlands Commissioning Support Unit or the CCG as instructed by the CCG.
6. Patient level data will not be shared outside of the CCG, other than with their member GP Practices for each Practices own patients only 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 outside of this as set out within NHS Digital guidance applicable to each data set.
7. GP Practices may only re-identify data when they need to do so for direct care purposes.


GP data
i. Identifiable GP data is submitted to NHS Arden and Greater East Midlands Commissioning Support Unit.
ii. The data lands in a ring-fenced area for GP data only.
iii. A specific named individual within NHS Arden and Greater East Midlands Commissioning Support Unit acts on behalf of the GP practice. This person has access to a closed black box system (which includes a pseudonymisation process).
iv. The individual requests a pseudonymisation key from the DSCRO to use with the black box system. There will be a separate key specific to the pseudonymisation request and the key will only be used for that specific project. The key is specific to the pseudonymisation request. The access controls around the individual’s role does not give them access to the data once it has been passed on to the NHS Arden and Greater East Midlands Commissioning Support Unit.
v. The GP data is then pseudonymised using the black box and DSCRO issued key. The identifiable GP data is then deleted from the ring-fenced area.
vi. The data is then transferred into a separate part of NHS Arden and Greater East Midlands Commissioning Support Unit.
vii. NHS Arden and Greater East Midlands Commissioning Support Unit make a request to NHS Digital (DSCRO).
viii. The DSCRO send a mapping table to NHS Arden and Greater East Midlands Commissioning Support Unit.
ix. NHS Arden and Greater East Midlands Commissioning Support Unit overwrite the organisations specific pseudonymisation keys with the DSCRO provided keys.
x. The mapping table is then deleted.

Data Processor 2 – South Warwickshire GP Ltd
1. South Warwickshire GP Ltd will receive the linked pseudonymised primary care and secondary care data from Step 4, under Data Processor 1 processing activities from either NHS Arden and GEM CSU or from the CCG.
2. South Warwickshire GP Ltd will analyse the data with a focus on primary care and provide reports to the CCG and to the GP Practices as instructed by the CCG. South Warwickshire GP Ltd provide analytics to support population health management to help those providing patient care. The reports provide insight into a patient’s care and can highlight that a patient’s care needs to be reassessed to see if further intervention is required
3. Patient level data will not be shared outside of the CCG, other than with their member GP Practices for each Practices own patients only 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 outside of this as set out within NHS Digital guidance applicable to each data set.
4. GP Practices may only re-identify data when they need to do so for direct care purposes.
5. South Warwickshire GP Ltd will not link this data to any other data that they hold or have access to.

Data Processor 3 – South Warwickshire NHS Foundation Trust
1. South Warwickshire NHS Foundation Trust will receive the linked pseudonymised primary care and secondary care data from Step 4, under Data Processor 1 processing activities from either NHS Arden and GEM CSU or from the CCG.
2. South Warwickshire NHS Foundation Trust will analyse the data to give greater insight into population health and patient stratification and provide reports to the CCG and to the GP Practices as instructed by the CCG. The reports will provide insight that will raise suggestions about the direct care of the patient.
3. Patient level data will not be shared outside of the CCG, other than with their member GP Practices for each Practices own patients only 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 outside of this as set out within NHS Digital guidance applicable to each data set.
4. GP Practices may only re-identify data when they need to do so for direct care purposes.
5. South Warwickshire NHS Foundation Trust will not link this data to any other data that they hold or have access to.

Re-identification process for direct care
1. GP requires patient to be re-identified for the purpose of direct care
2. A re-id request is then automated through the CSU’s Business Intelligence (BI) Tool
3. The CSU assesses as to whether the request passes the specified Re-identification Process checks
4. If successful, the request is sent to the DSCRO for approval from the IAO/ IRO
5. DSCRO re-identifies the data item
6. National Data opt outs are not applied for the purpose of direct care
7. DSCRO send the identifiable data to the GP


GDPPR COVID-19 – CCG - Pseudo — DARS-NIC-435166-T9S8X

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

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

Sensitive: Sensitive

When:DSA runs 2021-04-01 — 2021-09-30 2021.03 — 2021.05.

Access method: One-Off, Frequent Adhoc Flow

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

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 South Warwickshire CCG; IV — DARS-NIC-82404-V2S5B

Type of data: information not disclosed for TRE projects

Opt outs honoured: Yes - patient objections upheld, No - DSfC for Invoice Validation Purposes, Identifiable (Section 251, Does not include the flow of confidential data, Section 251 NHS Act 2006)

Legal basis: Section 251 approval is in place for the flow of identifiable data, National Health Service Act 2006 - s251 - 'Control of patient information'. , 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(2)(b)(ii); National Health Service Act 2006 - s251 - 'Control of patient information'.

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

Sensitive: Sensitive

When:DSA runs 2019-06-08 — 2022-06-07 2018.06 — 2021.03.

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

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

Sublicensing allowed: No

Datasets:

  1. SUS for Commissioners

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.

The legal basis for this to occur is under Section 251 of NHS Act 2006.

Invoice Validation with be conducted by Arden and GEM CSU.
The CCG are advised by Arden and GEM CSU 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 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.

The legal basis for this to occur is under Section 251 of NHS Act 2006 (CAG 7-04(a)).

Risk Stratification will be conducted by Arden and GEM CSU.

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.

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.

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)

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. Identifiable SUS+ Data is obtained from the SUS+ Repository to 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) in the Arden and GEM CSU.
3. The CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Validating that the Clinical Commissioning Group is responsible for payment for the care of the individual by using SUS+ and/or backing flow data.
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. are in relation to a patient registered with a 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 that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Arden and GEM CSU CEfF team and the provider meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.

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 Arden and GEM CSU, who hold the SUS+ data within the secure Data Centre on N3.
3. Identifiable GP Data is securely sent from the GP system to Arden and GEM CSU.
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 Arden and GEM CSU has completed the processing, the CCG can access the online system via a secure connection to access the data pseudonymised at patient level.


DSfC - NHS Warwickshire North CCG; IV — DARS-NIC-82396-W4F5T

Type of data: information not disclosed for TRE projects

Opt outs honoured: Yes - patient objections upheld, No - DSfC for Invoice Validation Purposes, Identifiable (Section 251, Section 251 NHS Act 2006)

Legal basis: Section 251 approval is in place for the flow of identifiable data, 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 2019-06-08 — 2022-06-07 2018.06 — 2021.03.

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

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

Sublicensing allowed: No

Datasets:

  1. SUS for Commissioners

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.
The legal basis for this to occur is under Section 251 of NHS Act 2006.
Invoice Validation with be conducted by Arden and GEM CSU.
The CCG are advised by Arden and GEM CSU whether payment for invoices can be made or not.

Risk Stratitification
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.
The legal basis for this to occur is under Section 251 of NHS Act 2006 (CAG 7-04(a)).
Risk Stratification will be conducted by Arden and GEM CSU.

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
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.

Outputs:

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.

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).

All access to data is auditable by NHS Digital.

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 (Identifiable data)
1. Identifiable SUS Data is obtained from the SUS Repository to 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) in the Arden and GEM CSU.
3. The CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Checking the individual is registered to a particular Clinical Commissioning Group (CCG) 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. are in relation to a patient registered with a 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 that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between the CSU CEfF team and the provider meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management

Invoice Validation (pseudonymised data)
1. Identifiable SUS+ Data is obtained from the SUS+ Repository to 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) in the Arden and GEM CSU.
3. The CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Validating that the Clinical Commissioning Group is responsible for payment for the care of the individual by using SUS+ and/or backing flow data.
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. are in relation to a patient registered with a 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 that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Arden and GEM CEfF team and the provider meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.


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 Arden and GEM CSU, who hold the SUS+ data within the secure Data Centre on N3.
3. Identifiable GP Data is securely sent from the GP system to Arden and GEM CSU.
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 Arden and GEM CSU has completed the processing, the CCG can access the online system via a secure connection to access the data pseudonymised at patient level.



DSfC - NHS Coventry and Rugby CCG; RS & IV — DARS-NIC-82378-M2B6C

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: Section 251 approval is in place for the flow of identifiable data, National Health Service Act 2006 - s251 - 'Control of patient information'. , 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(2)(b)(ii); National Health Service Act 2006 - s251 - 'Control of patient information'.

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

Sensitive: Sensitive

When:DSA runs 2019-06-08 — 2022-06-07 2018.06 — 2021.03.

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

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

Sublicensing allowed: No

Datasets:

  1. SUS for Commissioners

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.

The legal basis for this to occur is under Section 251 of NHS Act 2006.

Invoice Validation with be conducted by Arden and GEM CSU.

The CCG are advised by Arden and GEM CSU 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 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.

The legal basis for this to occur is under Section 251 of NHS Act 2006 (CAG 7-04(a)).

Risk Stratification will be conducted by Arden and GEM CSU.

Yielded Benefits:

N/A

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.

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.


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.

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)

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. Identifiable SUS+ Data is obtained from the SUS+ Repository to 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) in the Arden and GEM CSU.
3. The CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Validating that the Clinical Commissioning Group is responsible for payment for the care of the individual by using SUS+ and/or backing flow data.
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. are in relation to a patient registered with a 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 that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between Arden and GEM CSU CEfF team and the provider meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.

Risk Stratification (Prescribing Services Limited)
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 Limited, 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 Limited.
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 Limited has completed the processing, the CCG can access the online system via a secure connection to access the data pseudonymised at patient level.



3 CCGs within Coventry and Warwickshire STP - Comm, including GP data — DARS-NIC-238282-X0B6H

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(1) and s261(2)(b)(ii), Health and Social Care Act 2012 – s261(2)(b)(ii)

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

Sensitive: Sensitive

When:DSA runs 2019-06-01 — 2022-05-31 2018.10 — 2021.03.

Access method: Frequent Adhoc Flow, One-Off

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

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:


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 Sustainability Transformation Partnership (STP) area, which includes the following CCGs:
- NHS Coventry and Rugby CCG
- NHS South Warwickshire CCG
- NHS Warwickshire North CCG

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)
- Community Services Data Set (CSDS)
- Diagnostic Imaging Data Set (DIDS)
- National Cancer Waiting Times Monitoring Data Set (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 Arden and Great East Midlands Commissioning Support Unit (AGEM CSU)

Yielded Benefits:

The previous approval which permitted South Warwickshire CCG to analyse secondary care data linked to primary care (GP) data, provided significant benefit because the dataset was richer and enabled South Warwickshire CCG to analyse the full patient pathway across secondary care and primary care. For example, when they wanted to analyse the impact of projects that they have trialled where additional resources had been commissioned for specific cohorts of patients versus the pathway of patients who did not benefit from additional resources; they were able to more accurately evidence the benefit to the patients because of the richer dataset and were able then to justify funding wider roll-out of new services; or in some cases they were able to establish that the additional funding was not having the desired impact and enabled them to adjust the commissioned services. However, the CCG’s ability to utilise the previous approval was limited because of their own lack of resource. The STP CCGs recognise that they can make even greater use of the combined secondary and primary care datasets by utilizing the resource and skills of the two new data processors (South Warwickshire NHS Foundation Trust and South Warwickshire GP Federation Ltd (SWGP). In addition the larger STP footprint will enable better pathway analysis as it allows more benchmarking and comparisons to be made across the region to better understand the population’s needs. This is particularly pertinent following the coronavirus pandemic where prioritisation for restoration of services will be required as soon as possible and access to the data by both SWFT and the GP Federation to support the CCGs will aid restoration across the system and expedite this process. This will enable identification of the most at risk patients and target contact and intervention across the whole pathway – from out of hospital community, and primary care and acute secondary care.

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. 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:

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.


Patient level data will not be shared outside of the CCGs 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)

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
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 Commissioning:
• Patients who are normally registered and/or resident within the commissioners (including historical activity where the patient was previously registered or resident in another commissioner).
and/or
• Patients treated by a provider where the commissioner is the host/co-ordinating commissioner and/or has the primary responsibility for the provider services in the local health economy – this is only for commissioning and relates to both national and local flows.
and/or
• Activity identified by the provider and recorded as such within national systems (such as SUS+) as for the attention of the commissioner - this is only for commissioning and relates to both national and local flows.



For clarity, any access by Ilkeston Community Hospital to 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+
2. Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Demand for Service
e. Diagnostic Service
f. Emergency Care
g. Experience, Quality and Outcomes
h. Mental Health
i. Other Not Elsewhere Classified
j. Population Data
k. Primary Care Services
l. 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 – NHS Arden & GEM CSU
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 NHS Arden & GEM CSU.
2. NHS Arden & GEM CSU add derived fields, link data and provide analysis to:
a. See patient journeys for pathways or service design, re-design and de-commissioning.
b. Check recorded activity against contracts or invoices and facilitate discussions with providers.
c. Undertake population health management
d. Undertake data quality and validation checks
e. Thoroughly investigate the needs of the population
f. Understand cohorts of residents who are at risk
g. Conduct Health Needs Assessments
3. Allowed linkage is between the data sets contained within point 1.
4. NHS Arden & GEM CSU then pass the processed, pseudonymised and linked data to the CCG.
5. Aggregation of required data for CCG management use will be completed by NHS Arden & GEM CSU or the CCG as instructed by the CCG.
6. 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 as set out within NHS Digital guidance applicable to each data set.


DSfC - NHS South Warwickshire - Comm (GP federation) — DARS-NIC-168692-Y5S4C

Type of data: information not disclosed for TRE projects

Opt outs honoured: No - data flow is not identifiable, Anonymised - ICO Code Compliant (Section 251, 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(1) and s261(2)(b)(ii), Health and Social Care Act 2012 – s261(2)(b)(ii)

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

Sensitive: Sensitive

When:DSA runs 2019-05-01 — 2022-04-30 2018.06 — 2021.03.

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

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

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 Cancer Waiting Times Monitoring DataSet (NCWTMDS)
  26. Improving Access to Psychological Therapies Data Set_v1.5
  27. Civil Registrations of Death
  28. Community Services Data Set (CSDS)
  29. Diagnostic Imaging Data Set (DID)
  30. Improving Access to Psychological Therapies (IAPT) v1.5
  31. Mental Health and Learning Disabilities Data Set (MHLDDS)
  32. Mental Health Minimum Data Set (MHMDS)
  33. Mental Health Services Data Set (MHSDS)

Objectives:

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 Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- Community Services Data Set (CSDS)
- Diagnostic Imaging Data Set (DIDS)
- National Cancer Waiting Times Monitoring Data Set (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
§ 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’s own analysts or by NHS Arden and Greater East Midlands Commissioning Support Unit.

Yielded Benefits:

The benefits of linking in primary care data have been realised as expected. The inclusion of primary care data enables achievement to be assessed more accurately, and to make more targeted commissioning decisions.

Expected Benefits:

Commissioning
There are several key benefits of having a linked dataset:
1. Better forecasting and demand modelling: Having a linked dataset enables more robust demand modelling through having a joined up picture of service usage. A linked dataset will inform and enable decisions about adapting and prioritising the delivery of services between the individual providers of South Warwickshire CCG.
2. Financial planning: A linked dataset will allow better analysis of the costs of different types of care that are currently being delivered. This will allow the most efficient and optimal mix of care to be planned and subsequently provided. It will also support the delivery of new contract types, covering multiple providers.
3. Linked data will provide a more accurate picture of health and care service usage by individuals across the CCG, thus enabling services to be adapted and delivered in a way which targets those at greatest risk and aims to reduce their likelihood of having a significant health event or deteriorating.
4. Better monitoring of performance: A linked dataset will enable more accurate monitoring of the overall health and care system across South Warwickshire, from a patient / service user perspective. This will ensure that patients / service-users are at the centre of the health and care system and also enable alternative measures of performance and more effective monitoring to be put in place.
5. Performance monitoring for the Outcomes Framework for the Out of Hospital programme: A linked data set will support the key Out of Hospital objective of moving towards a whole-population Outcomes Framework. In order to contract and monitor achievement of outcomes accurately, measurement of outcomes must be robust but, without a linked dataset, outcomes can only be partially captured based on a specific service or care setting. This means that outcomes measurement will not be as robust.

All of the above will contribute towards the delivery of a more joined up, more efficient and higher quality care service and improved population outcomes.

Outputs:

Commissioning
Commissioner reporting:
• Re-ablement
• Emergency admissions analysis
• Reduction in length of stay and transfer of care delays
• Planned care by POD view - activity plan & actuals YTD.
• Identify baselines to measure future new service
• Production of aggregated reports for integrated business intelligence
• Production of project / programme level dashboards
• Patient population profiling


1. Supporting Quality Innovation Productivity and Prevention (QIPP) to review demand management and pathways
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. Enables monitoring of: CCG outcome measures
a. Non-financial validation of activity
b. Successful delivery of integrated care
c. Checking frequent or multiple attendances to improve early intervention and avoid admission
d. Case Management
e. Care service planning
f. Commissioning and performance management
g. List size verification by GP provider
h. Understanding care of patients in nursing homes

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.
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)

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.


Commissioning
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS+
2. Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Demand for Service
e. Diagnostic Service
f. Emergency Care
g. Experience, Quality and Outcomes
h. Mental Health
i. Other Not Elsewhere Classified
j. Population Data
k. Primary Care Services
l. Public Health Screening
3. Mental Health Services Data Set (MHSDS)
4. Maternity Services Data Set (MSDS)
5. Improving Access to Psychological Therapy (IAPT)
6. Child and Young People Health Service (CYPHS)
7. Community Services Data Set (CSDS)
8. Diagnostic Imaging Data Set (DIDS)
9. National Cancer Waiting Times Monitoring Data Set (CWT)
Data quality management and pseudonymisation is completed within the DSCRO using the Open Pseudonymiser tool and is then disseminated as follows:
Data Processor 1 – NHS Arden and Greater East Midlands Commissioning Support Unit
1. Pseudonymised SUS+, Local Provider data, Mental Health data (MHMDS), 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 NHS Arden and Greater East Midlands Commissioning Support Unit
2. NHS Arden and Greater East Midlands Commissioning Support Unit land the data only in the secure management environment. The data is then sent directly to the CCG.
3. Identifiable GP Data (primary care data) is securely sent from the GP systems to South Warwickshire GP Federation Ltd. South Warwickshire GP Federation Ltd act as data processor on behalf of the GP practices.
4. South Warwickshire GP Federation Ltd pseudonymise the primary care data using the Open Pseudonymiser tool, on behalf of the GP Practices, using the encryption key provided by the DSCRO specific to each project.
5. South Warwickshire GP Federation Ltd then pass the pseudonymised primary care data in consistently pseudonymised form at patient level to the CCG via secure FTP.
6. The CCG undertake linkage of the data.
7. Allowed linkage is between the data sets contained within point 1 and 6.
8. The CCG analyse the data to:
a. See patient journeys for pathways or service design, re-design and de-commissioning.
b. Check recorded activity against contracts or invoices and facilitate discussions with providers.
c. Undertake population health management
d. Undertake data quality and validation checks
e. Thoroughly investigate the needs of the population
f. Understand cohorts of residents who are at risk
g. Conduct Health Needs Assessments
h. Produce high level reports
9. Aggregation of required data for CCG management use will be completed by the CCG.
10. 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 as set out within NHS Digital guidance applicable to each data set.
The CCG will be responsible for linking the data but will not have access to the pseudonymisation tool, and will have no means or requirement to re-identify any data. The Encryption key will only be shared by the DSCRO with South Warwickshire GP Federation, who will have documented responsibility to use the key to ensure that the agreed data for linkage is pseudonymised. These individuals are contractually bound to adhere to organisational policies and procedures for safe management of the data.

South Warwickshire GP Federation will not receive any record level output from the linked data; only aggregate with small number suppression


GDPPR COVID-19 – CCG - Pseudo — DARS-NIC-390198-L6W9C

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 2020-09-01 — 2021-03-31 2021.01 — 2021.02.

Access method: One-Off, Frequent Adhoc Flow

Data-controller type: NHS COVENTRY AND WARWICKSHIRE CCG, NHS COVENTRY AND WARWICKSHIRE ICB - B2M3M

Sublicensing allowed: No

Datasets:

  1. GPES Data for Pandemic Planning and Research (COVID-19)
  2. 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).