NHS Digital Data Release Register - reformatted

NHS Devon Icb - 15n projects

• DSfC - NHS Devon CCG - Comm, RS & IV
• GDPPR COVID-19 – CCG - Pseudo
• DSfC - NHS Devon CCG and NHS Kernow CCG - Commissioning
• DSfC - NHS Devon CCG: Comm, RS & IV
• DSfC - Northern Eastern and Western Devon CCG IV, RS

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

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DSfC - NHS Devon CCG - Comm, RS & IV — DARS-NIC-454210-X7N1F

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, and Non Sensitive, and Non-Sensitive

When:DSA runs 2021-04-29 — 2024-04-28 2021.04 — 2021.05.

Access method: One-Off, Frequent Adhoc Flow

Data-controller type: NHS DEVON CCG, NHS DEVON ICB - 15N

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. Personal Demographic Service
26. Population Data-Local Provider Flows
27. Primary Care Services-Local Provider Flows
28. Public Health and Screening Services-Local Provider Flows
29. Summary Hospital-level Mortality Indicator
30. SUS for Commissioners
31. National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
32. Improving Access to Psychological Therapies Data Set_v1.5
33. Adult Social Care
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+) and Personal Demographic (PDS) data, which is received into a secure Controlled Environment for Finance (CEfF). The SUS+ and PDS 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) and determining if the CCG is the responsible commissioner for the patient.

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

Invoice Validation will be conducted by NHS Devon CCG


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+) 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 NHS Devon CCG

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

The CCGs commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.

The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:
- Secondary Uses Service (SUS+)
- Local Provider Flows
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
- Mental Health Minimum Data Set (MHMDS)
- Mental Health Learning Disability Data Set (MHLDDS)
- Mental Health Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- 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)
- Personal Demographics Service (PDS)
- 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 Devon CCG and North of England Commissioning Support Unit.

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.

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.

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.
5. Support validating financial payments for contracted and non-contracted activity, determining if the CCG is the responsible commissioner for the patient.

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)

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.

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 Devon 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 Devon 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 Devon 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 Devon 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

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).

DELT Shared Services Ltd provide 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.

Stem Group 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.

Pulsant and IT Professional Services Ltd 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
1. Identifiable SUS+ and PDS Data is obtained by the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO / CSU pushes a one-way data flow of SUS+ and PDS data into the Controlled Environment for Finance (CEfF) located in the CCG.
3. The CEfF also receive backing data from the provider.
4. The CEfF conduct the following processing activities 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, it will be checked against national NHS and local commissioning policies, as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:
i. In line with Payment by Results tariffs
ii. In relation to a patient registered with the CCG, GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance. 
5. The CCG are notified by the CEfF that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved.

RISK STRATIFICATION
1. Identifiable SUS+ data is 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 the CCG, who securely hold the SUS+ data. Data may be landed in North of England Commissioning Support Unit before being passed to the CCG.
3. Identifiable GP Data is securely sent from the GP system to the CCG.
4. SUS+ data is linked to GP data in the risk stratification tool by the data processor.
5. As part of the risk stratification processing activity, GPs have access to the risk stratification tool within the data processor, which highlights patients with whom the GP has a legitimate relationship and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
6. Once the CCG has completed the processing, access is available within the CCG through 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 Devon CCG and North of England 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), National Diabetes Audit (NDA), Patient Reported Outcome Measures (PROMs), 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 North of England Commissioning Support Unit.
2. North of England Commissioning Support Unit add derived fields by using existing data, 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. North of England Commissioning Support Unit then pass the processed, pseudonymised and linked data to the CCG who further process the data.
5. Aggregation of required data for CCG management use will be completed by North of England Commissioning Support Unit 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.

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GDPPR COVID-19 – CCG - Pseudo — DARS-NIC-385396-J1Z4V

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 2020-08-18 — 2021-03-31 2021.01 — 2021.05.

Access method: One-Off, Frequent Adhoc Flow

Data-controller type: NHS DEVON CCG, NHS DEVON ICB - 15N

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.

Yielded Benefits:

The CCG has so far not been able to receive the data from the CSU DSCRO, hence no yielded benefits as yet.

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).

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DSfC - NHS Devon CCG and NHS Kernow CCG - Commissioning — DARS-NIC-348357-W0P1W

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(5)(d), 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 2020-03-06 — 2023-03-05 2020.04 — 2021.05.

Access method: Frequent Adhoc Flow, One-Off

Data-controller type: NHS DEVON CCG, NHS KERNOW CCG, CORNWALL COUNCIL, NHS DEVON CCG, NHS KERNOW CCG, NHS CORNWALL AND THE ISLES OF SCILLY ICB - 11N, NHS DEVON ICB - 15N, CORNWALL COUNCIL, NHS CORNWALL AND THE ISLES OF SCILLY ICB - 11N, NHS DEVON ICB - 15N

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. Experience, Quality and Outcomes-Local Provider Flows
13. Improving Access to Psychological Therapies Data Set
14. Maternity Services Data Set
15. Mental Health and Learning Disabilities Data Set
16. Mental Health Minimum Data Set
17. Mental Health Services Data Set
18. Mental Health-Local Provider Flows
19. National Cancer Waiting Times Monitoring DataSet (CWT)
20. National Diabetes Audit
21. Other Not Elsewhere Classified (NEC)-Local Provider Flows
22. Patient Reported Outcome Measures
23. Population Data-Local Provider Flows
24. Primary Care Services-Local Provider Flows
25. Public Health and Screening Services-Local Provider Flows
26. SUS for Commissioners
27. e-Referral Service for Commissioning
28. Personal Demographic Service
29. Summary Hospital-level Mortality Indicator
30. Medicines dispensed in Primary Care (NHSBSA data)
31. National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
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:

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.

NHS Devon & NHS Kernow CCGs work together on a collaborative basis. This request is for each CCG to receive data for the entire region covered by both the CCGs. Receiving data for the entire region will allow the CCGs to support each other in delivering their commissioning agendas, as well as supporting the newly established primary care networks across the region. The CCGs will receive datasets on a collaborative basis across their region, to be used for either collaborative reporting across the region, or at individual CCG level as required. This assists to ensure delivery of care in the right place for patients who may move and change services across CCGs. The CCGs will work proactively and collaboratively to redesign services across boundaries to integrate services. Collaborative sharing is required for CCGs to understand these requirements.

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)
- Civil Registries Data (CRD) (Births)
- Civil Registries Data (CRD) (Deaths)
- National Diabetes Audit (NDA)
- Patient Reported Outcome Measures (PROMs)

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 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 NHS South Central and West Commissioning Support Unit

Legal basis for processing:
Data is being processed under Article 6(1(e ) (processing is necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller)
And
Article 9(2)(h) ((processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3)

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.
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.

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.
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.

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.

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)

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 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 Devon and Kernow CCG region (including historical activity where the patient was previously registered or resident in another commissioner).
and/or
• Patients treated by a provider where Devon and Kernow 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 Devon and Kernow CCG - this is only for commissioning and relates to both national and local flows.

DELT Shared Services Ltd 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.

Stem Group, Royal Cornwall Hospitals Acute Trust and University Hospitals Bristol NHS Foundation Trust 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.

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).

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)

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

NHS South, Central and West 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), National Diabetes Audit (NDA) and Patient Reported Outcome Measures (PROMs) only is held until points 2-8 are completed.
2. NHS South, Central and West Commissioning Support Unit receives GP data. GP Data is received as follows:
o Identifiable GP data is submitted to NHS South, Central and West Commissioning Support Unit.
o The identifiable data lands in a ring-fenced area for GP data only.
o The GP data is pseudonymised using a pseudonymisation tool, different to that used by the DSCRO.
o There is a Data Processing Agreement in place between the GP and NHS South, Central and West Commissioning Support Unit. A specific named individual within NHS South, Central and West Commissioning Support Unit acts on behalf of the GP.
o This individual has access to a black box. The pseudonymised data is passed through the black box process where the pseudonymisation is mapped to the pseudonymisation used by the DSCRO.
o Once mapped, the data is passed into NHS South, Central and West Commissioning Support, but before NHS South, Central and West Commissioning Support Unit will receive the data from the ring-fenced area, they require confirmation that the identifiable data has been deleted.
o NHS South, Central and West Commissioning Support Unit are then sent the pseudonymised GP data with the pseudo algorithm specific to them.
3. NHS South, Central and West Commissioning Support Unit also receive a flow of social care data. Social Care data is received in one of the following 2 ways:
o Pseudonymised:
- Social Care data is pseudonymised within the provider using a pseudonymisation tool, different to that used by the DSCRO. The provider requests a pseudonymisation key from the DSCRO. The key can only be used once. The key is specific to the Local Authority and to that specific date.
- The pseudonymised data lands in a ring-fenced area for social care data only.
- There is a Data Processing Agreement in place between the Provider and NHS South, Central and West Commissioning Support Unit. A specific named individual within NHS South, Central and West Commissioning Support Unit acts on behalf of the Provider.
- This individual has access to a black box. The pseudonymised data is passed through the black box process where the pseudonymisation is mapped to the pseudonymisation used by the DSCRO.
- The data is then passed into the non-ringfenced area with the pseudo algorithm specific to them.
o Identifiable:
- Identifiable social care data is submitted to NHS South, Central and West Commissioning Support Unit.
- The identifiable data lands in a ring-fenced area for social care data only.
- The social care data is pseudonymised using a pseudonymisation tool, different to that used by the DSCRO.
- There is a Data Processing Agreement in place between the Local Authority and NHS South, Central and West Commissioning Support Unit. A specific named individual within NHS South, Central and West Commissioning Support Unit acts on behalf of the provider.
- This individual has access to a black box. The pseudonymised data is passed through the black box process where the pseudonymisation is mapped to the pseudonymisation used by the DSCRO.
- Once mapped, the data is passed into NHS South, Central and West Commissioning Support, but before NHS South, Central and West Commissioning Support Unit will receive the data from the ring-fenced area, they require confirmation that the identifiable data has been deleted.
- NHS South, Central and West Commissioning Support Unit are then sent the pseudonymised social care data with the pseudo algorithm specific to them.
4. Once the pseudonymised GP data and social care data is received, NHS South, Central and West Commissioning Support Unit make a request to the DSCRO.
5. The DSCRO check the dates of the key generation.
6. The DSCRO then send a mapping table to NHS South, Central and West Commissioning Support Unit
7. NHS South, Central and West Commissioning Support Unit then overwrite the organisation specific keys with the DSCRO key.
8. The mapping table is then deleted.
9. The DSCRO pass the 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), National Diabetes Audit (NDA) and Patient Reported Outcome Measures (PROMs) only securely to NHS South, Central and West Commissioning Support Unit for the addition of derived fields, linkage of data sets and analysis.
10. Social Care Data and GP Data is then linked to the data sets listed within point 9. NHS South, Central and West Commissioning Support Unit then analyse the data to do the following:
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
11. NHS South, Central and West Commissioning Support Unit then pass the processed, pseudonymised data to the CCGs for the further addition of derived fields, linkage of data sets and 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
12. Aggregation of required data for CCG management use will be completed by the CCGs or NHS South, Central and West Commissioning Support Unit as instructed by the CCGs.
13. Patient level data will not be shared outside of the CCGs and will only be shared within the CCGs 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.

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DSfC - NHS Devon CCG: Comm, RS & IV — DARS-NIC-264169-J6F6T

Type of data: information not disclosed for TRE projects

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

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

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

Sensitive: Sensitive, and Non Sensitive, and Non-Sensitive

When:DSA runs 2019-04-01 — 2022-03-31 2019.03 — 2021.05.

Access method: Frequent Adhoc Flow, One-Off

Data-controller type: NHS DEVON CCG, NHS DEVON ICB - 15N

Sublicensing allowed: No

Datasets:

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

Objectives:

Invoice Validation
Invoice validation is part of a process by which providers of care or services get paid for the work they do.
Invoices are submitted to the Clinical Commissioning Group (CCG) so they are able to ensure that the activity claimed for
each patient is their responsibility. This is done by processing and analysing Secondary User Services (SUS+) data, which is
received into a secure Controlled Environment for Finance (CEfF). The SUS+ data is identifiable at the level of NHS number.
The NHS number is only used to confirm the accuracy of backing-data sets and will not be used further.
The legal basis for this to occur is under Section 251 of NHS Act 2006.
Invoice Validation with be conducted by NHS Devon CCG

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

Commissioning
The NHS and local councils have come together in 44 areas covering all of England to develop proposals to improve health
and care. They have formed new partnerships-known as sustainability and transformation partnerships - to plan jointly
for the next few years.
Sustainability and transformation partnerships build on collaborative work that began under the NHS Shared Planning
Guidance for 2016/17-2020/21, to support implementation of the Five Year Forward View. They are supported by six
national health and care bodies: NHS England; NHS Improvement; the Care Quality Commission (CQC); Health Education
England (HEE); Public Health England (PHE) and the National Institute for Health and Care Excellence (NICE).
NHS Northern Eastern and Western Devon CCG and NHS South Devon and Torbay CCG are part of the Devon Sustainable
Transformation Partnership and will merge into NHS Devon CCG on the 1st April 2019. The STP is responsible for implementing large parts of the 5 year forward view from NHS
England. The STP is implementing several initiatives:
- Putting the patient at the heart of the health system
- Working across organisational boundaries to deliver care and including social care, public Health, providers and GPs as
well as CCGs
- Reviewing patient pathways to improve patient experience whilst reducing costs e.g. reduce the number of standard tests
a patient may have and only have the ones they need
- Planning the demand and capacity across the healthcare system across the CCG to ensure we have the right buildings,
services and staff to cope with demand whilst reducing the impact on costs
- Working to prevent or capture conditions early as they are cheaper to treat
- Introduce initiatives to change behaviours e.g. move more care into the community
- Patient pathway planning for the above
To ensure the patient is at the heart of care, the STP is focussing on where services are required across the geographical
region. This assists to ensure delivery of care in the right place for patients who may move and change services across the CCG.
Collaborative sharing is required for CCGs to understand these requirements.
The CCG will 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 STP area.
The CCG commissions 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 (CWT)
- Civil Registries Data (CRD) (Births and Deaths)

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

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.

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
6. healthcare outcomes
All of the above lead to improved patient experience through more effective commissioning of services.

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

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.

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

Commissioning
1. Commissioner reporting:
a. Summary by provider view - plan & actuals year to date (YTD).
b. Summary by Patient Outcome Data (POD) view - plan & actuals YTD.
c. Summary by provider view - activity & finance variance by POD.
d. Planned care by provider view - activity & finance plan & actuals YTD.
e. Planned care by POD view - activity plan & actuals YTD.
f. Provider reporting.
g. Statutory returns.
h. Statutory returns - monthly activity return.
i. Statutory returns - quarterly activity return.
j. Delayed discharges.
k. Quality & performance referral to treatment reporting.
2. Readmissions analysis.
3. Production of aggregate reports for CCG Business Intelligence.
4. Production of project / programme level dashboards.
5. Monitoring of acute / community / mental health quality matrix.
6. Clinical coding reviews / audits.
7. Budget reporting down to individual GP Practice level.
8. GP Practice level dashboard reports include high flyers.
9. Comparators of CCG performance with similar CCGs as set out by a specific range of care quality and performance measures detailed activity and cost reports
10. Data Quality and Validation measures allowing data quality checks on the submitted data
11. Contract Management and Modelling
12. Patient Stratification, such as:
o Patients at highest risk of admission
o Most expensive patients (top 15%)
o Frail and elderly
o Patients that are currently in hospital
o Patients with most referrals to secondary care
o Patients with most emergency activity
o Patients with most expensive prescriptions
o Patients recently moving from one care setting to another
i. Discharged from hospital
ii. Discharged from community
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.

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.


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

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

No patient level data will be linked other than as specifically detailed within this agreement. Data will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement. The data to be released from NHS Digital will not be national data, but only that data relating to the specific locality and that data required by the applicant.

NHS Digital reminds all organisations party to this agreement of the need to comply with the Data Sharing Framework Contract requirements, including those regarding the use (and purposes of that use) by “Personnel” (as defined within the Data Sharing Framework Contract ie: employees, agents and contractors of the Data Recipient who may have access to that data)

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


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 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 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 NHS Devon CCG (including historical activity where the patient was previously registered or resident in another commissioner).
and/or
• Patients treated by a provider where NHS Devon 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 Devon 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 NHS Devon CCG (including historical activity where the patient was previously registered or resident in another commissioner)

For the purpose of Invoice Validation:
• CCG of residence and/or registration

DELT Shared Services Ltd 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.

Stem Group 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.

Identifiable data will only be disclosed:
1) where the requesting Data Controller’s Caldicott Guardian/Senior Approving Officer has approved the disclosure
2) where the DSCRO Information Risk Owner has approved the disclosure
3) to requestor/recipients specified by the Data Controller
4) to recipients that have a legitimate relationship with the individuals identified by the data, e.g. clinician
5) using mechanisms and routes that are secure and have an appropriate legal basis for holding identifiable data
6) where there is a legal basis and it is covered by a Data Sharing Agreement that justifies its use or the data subject has consented or where there is a separate legal basis for making the dataset identifiable enabling the re-identification to take place
7) whilst continuing to respect the data subject’s preferences for data sharing

In order for identifiable data to be disclosed, all seven requirements must be met.

Where identifiable data for the same dataset to the same organisation is released by NHS Digital (via a DSCRO), relevant controls must be in place locally by the recipient organisation to ensure that identifiable data is stored separately, under strict access control provisions, from its original anonymised in accordance with the ICOACoP form and used only for the specific purpose stipulated in this agreement. There must be no efforts made by the recipient organisation to link these datasets.

Local Identifiers:
If a Data Controller organisation (or the Data Processor working on their behalf):
a. only receives a DSCRO disseminated identifiable (NHS Number) flow, then it can receive clear local identifiers.
b. receives and pseudonymised flow, then clear local identifiers can be included and used only for the purpose outlined within the Data Sharing Agreement
c. receives both DSCRO disseminated identifiable and pseudonymised flows, the identifiable flow must have the local identifiers pseudonymised or removed.

Invoice Validation
1. Identifiable SUS+ Data is obtained from the SUS+ Repository by the Data Services for Commissioners Regional Office
(DSCRO).
2. The DSCRO pushes a one-way data flow of SUS+ data into the Controlled Environment for Finance (CEfF) located in NHS Devon CCG.
3. The CEfF conduct the following processing activities 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. In relation to a patient registered with the CCG GP or resident within the CCG area.
4. The CCG are notified by the CEfF that the invoice has been validated and can be paid. Any discrepancies or nonvalidated
invoices are investigated and resolved.
Invoice Validation work is only undertaken once. There is no duplication of the work. The CCG will only receive data
related to that CCG.

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 NHS Devon CCG, who hold the SUS+ data
within the secure Data Centre on N3.
3. Identifiable GP Data is securely sent from the GP system to the CCG.
4. SUS+ data is linked to GP data in the risk stratification tool by the data processor.
5. As part of the risk stratification processing activity, GPs have access to the risk stratification tool within the data
processor, which highlights patients with whom the GP has a legitimate relationship and have been classed as at risk. The
only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be
completed by the GP on their own systems.
6. Once the CCG has completed the processing, access is available through the online system via a secure N3 connection to
access the data pseudonymised at patient level.
Risk Stratification work is only undertaken once. There is no duplication of the work.

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 (CWT)
12. Civil Registries Data (CRD)

Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
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 (CWT) and Civil Registries Data (CRD) only is securely transferred from the DSCRO to the CCG.
2. The CCG then 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. Aggregation of required data for CCG management use will be completed by the CCG.
5. Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared as set out within NHS Digital guidance applicable to each data set.

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DSfC - Northern Eastern and Western Devon CCG IV, RS — DARS-NIC-46287-C8S9C

Type of data: information not disclosed for TRE projects

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

Legal basis: Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 – s261(7), Health and Social Care Act 2012 – s261(7)

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

Sensitive: Sensitive

When:DSA runs 2018-12-01 — 2021-11-30 2018.06 — 2020.01.

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

Data-controller type: NHS DEVON CCG, NHS DEVON ICB - 15N

Sublicensing allowed: No

Datasets:

1. Community-Local Provider Flows
2. Demand for Service-Local Provider Flows
3. Emergency Care-Local Provider Flows
4. Improving Access to Psychological Therapies Data Set
5. Mental Health and Learning Disabilities Data Set
6. Mental Health Minimum Data Set
7. Mental Health Services Data Set
8. Other Not Elsewhere Classified (NEC)-Local Provider Flows
9. Population Data-Local Provider Flows
10. Public Health and Screening Services-Local Provider Flows
11. SUS for Commissioners

Objectives:

Invoice Validation
As an approved Controlled Environment for Finance (CEfF), the CCG receives SUS data identifiable at the level of NHS number according to S.251 CAG 7-07(a) and (b)/2013. The data is required for the purpose of invoice validation. The NHS number is only used to confirm the accuracy of backing-data sets and will not be shared outside of the CEfF.

Risk Stratification
To use SUS data identifiable at the level of NHS number according to S.251 CAG 7-04(a) (and Primary Care Data) for the purpose of Risk Stratification. Risk Stratification provides a forecast of future demand by identifying high risk patients. This enables commissioners to initiate proactive management plans for patients that are potentially high service users. Risk Stratification enables General Practitioners (GPs) to better target intervention in Primary Care.
Risk Stratification will be conducted by Northern Eastern and Western Devon CCG


Commissioning
To use pseudonymised data to provide intelligence to support commissioning of health services. 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.
The CCGs commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.
The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:
- Secondary Uses Service (SUS)
- Local Provider Flows
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
- Mental Health Minimum Data Set (MHMDS)
- Mental Health Learning Disability Data Set (MHLDDS)
- Mental Health Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- Diagnostic Imaging Data Set (DIDS)
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 Northern Eastern and Western Devon CCG

Yielded Benefits:

Expected Benefits:

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

Risk Stratification
Risk stratification promotes improved case management in primary care and will lead to the following benefits being realised:
1. Improved planning by better understanding patient flows through the healthcare system, thus allowing commissioners to design appropriate pathways to improve patient flow and allowing commissioners to identify priorities and identify plans to address these.
2. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services and early intervention of appropriate care.
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. 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.
5. Better understanding of the health of and the variations in health outcomes within the population to help understand local population characteristics.
All of the above lead to improved patient experience through more effective commissioning of services.

Commissioning
1. Supporting Quality Innovation Productivity and Prevention (QIPP) to review demand management, integrated care and pathways.
a. Analysis to support full business cases.
b. Develop business models.
c. Monitor In year projects.
2. Supporting Joint Strategic Needs Assessment (JSNA) for specific disease types.
3. Health economic modelling using:
a. Analysis on provider performance against 18 weeks wait targets.
b. Learning from and predicting likely patient pathways for certain conditions, in order to influence early interventions and other treatments for patients.
c. Analysis of outcome measures for differential treatments, accounting for the full patient pathway.
d. Analysis to understand emergency care and linking A&E and Emergency Urgent Care Flows (EUCC).
4. Commissioning cycle support for grouping and re-costing previous activity.
5. Enables monitoring of:
a. CCG outcome indicators.
b. 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.

Outputs:

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

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

Commissioning
1. Commissioner reporting:
a. Summary by provider view - plan & actuals year to date (YTD).
b. Summary by Patient Outcome Data (POD) view - plan & actuals YTD.
c. Summary by provider view - activity & finance variance by POD.
d. Planned care by provider view - activity & finance plan & actuals YTD.
e. Planned care by POD view - activity plan & actuals YTD.
f. Provider reporting.
g. Statutory returns.
h. Statutory returns - monthly activity return.
i. Statutory returns - quarterly activity return.
j. Delayed discharges.
k. Quality & performance referral to treatment reporting.
2. Readmissions analysis.
3. Production of aggregate reports for CCG Business Intelligence.
4. Production of project / programme level dashboards.
5. Monitoring of acute / community / mental health quality matrix.
6. Clinical coding reviews / audits.
7. Budget reporting down to individual GP Practice level.
8. GP Practice level dashboard reports include high flyers.

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. Access is limited to those substantive employees with authorised user accounts used for identification and authentication.

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

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

No record level data will be linked other than as specifically detailed within this application/agreement. Data will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement. The data to be released from NHS Digital will not be national data, but only that data relating to the specific locality of interest of the applicant.
The DSCRO (part of NHS Digital) will apply Type 2 objections before any identifiable data leaves the DSCRO.

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

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


Commissioning
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS
2. Local Provider Flows (received directly from providers)
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
3. Mental Health Minimum Data Set (MHMDS)
4. Mental Health Learning Disability Data Set (MHLDDS)
5. Mental Health Services Data Set (MHSDS)
6. Maternity Services Data Set (MSDS)
7. Improving Access to Psychological Therapy (IAPT)
8. Child and Young People Health Service (CYPHS)
9. Diagnostic Imaging Data Set (DIDS)
Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
Data Processor 1 – Northern Eastern and Western Devon CCG
1) Pseudonymised SUS, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young People’s Health data (CYPHS) and Diagnostic Imaging data (DIDS) only is securely transferred from the DSCRO to Northern Eastern and Western Devon CCG.
2) Northern Eastern and Western Devon CCG add derived fields, link data and provide analysis.
3) Allowed linkage is between the data sets contained within point 1.
4) The CCG analyse the data to see patient journeys for pathways or service design, re-design and de-commissioning.
5) Aggregation of required data for CCG management use will be completed by Northern Eastern and Western Devon 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.

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