NHS Digital Data Release Register - reformatted

NHS Hertfordshire And West Essex Icb - 07h projects

DSfC - NHS West Essex - COMM and IV

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

DSfC - NHS West Essex - COMM and IV — DARS-NIC-55710-W8F8C

Type of data: information not disclosed for TRE projects

Opt outs honoured: N, Y, No - data flow is not identifiable, Yes - patient objections upheld, Anonymised - ICO Code Compliant, Identifiable (Section 251, 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), Section 251 approval is in place for the flow of identifiable data, National Health Service Act 2006 - s251 - 'Control of patient information'. , Health and Social Care Act 2012 – s261(7), Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 s261(7), 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

When:DSA runs 2019-07-01 — 2022-06-30 2018.06 — 2021.05.

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

Data-controller type: NHS WEST ESSEX CCG, NHS HERTFORDSHIRE AND WEST ESSEX ICB - 07H

Sublicensing allowed: No

Datasets:

Acute-Local Provider Flows
Ambulance-Local Provider Flows
Children and Young People Health
Community-Local Provider Flows
Demand for Service-Local Provider Flows
Diagnostic Imaging Dataset
Diagnostic Services-Local Provider Flows
Emergency Care-Local Provider Flows
Experience, Quality and Outcomes-Local Provider Flows
Improving Access to Psychological Therapies Data Set
Maternity Services Data Set
Mental Health and Learning Disabilities Data Set
Mental Health Minimum Data Set
Mental Health Services Data Set
Mental Health-Local Provider Flows
Other Not Elsewhere Classified (NEC)-Local Provider Flows
Population Data-Local Provider Flows
Primary Care Services-Local Provider Flows
Public Health and Screening Services-Local Provider Flows
SUS for Commissioners
Civil Registration - Births
Civil Registration - Deaths
Community Services Data Set
National Cancer Waiting Times Monitoring DataSet (CWT)
National Diabetes Audit
Patient Reported Outcome Measures
e-Referral Service for Commissioning
Personal Demographic Service
Summary Hospital-level Mortality Indicator
Medicines dispensed in Primary Care (NHSBSA data)
National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
Improving Access to Psychological Therapies Data Set_v1.5
Civil Registrations of Death
Community Services Data Set (CSDS)
Diagnostic Imaging Data Set (DID)
Improving Access to Psychological Therapies (IAPT) v1.5
Mental Health and Learning Disabilities Data Set (MHLDDS)
Mental Health Minimum Data Set (MHMDS)
Mental Health Services Data Set (MHSDS)
Patient Reported Outcome Measures (PROMs)
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 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 the CCG.

Commissioning
To use pseudonymised data to provide intelligence to support the commissioning of health services. The data (containing both clinical and financial information) is analysed so that health care provision can be planned to support the needs of the population within the CCG area.
The CCGs commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.
The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:
- Secondary Uses Service (SUS+)
- Local Provider Flows
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
- Mental Health Minimum Data Set (MHMDS)
- Mental Health Learning Disability Data Set (MHLDDS)
- Mental Health Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- Community Services Data Set (CSDS)
- Diagnostic Imaging Data Set (DIDS)
- National Cancer Waiting Times Monitoring Data Set (CWT)
The pseudonymised data is required to for the following purposes:
§ Population health management:
• Understanding the interdependency of care services
• Targeting care more effectively
• Using value as the redesign principle
§ Data Quality and Validation – allowing data quality checks on the submitted data
§ Thoroughly investigating the needs of the population, to ensure the right services are available for individuals when and where they need them
§ Understanding cohorts of residents who are at risk of becoming users of some of the more expensive services, to better understand and manage those needs
§ Monitoring population health and care interactions to understand where people may slip through the net, or where the provision of care may be being duplicated
§ Modelling activity across all data sets to understand how services interact with each other, and to understand how changes in one service may affect flows through another
§ Service redesign
§ Health Needs Assessment – identification of underlying disease prevalence within the local population
§ Patient stratification and predictive modelling - to identify specific patients at risk of requiring hospital admission and other avoidable factors such as risk of falls, computed using algorithms executed against linked de-identified data, and identification of future service delivery models

The pseudonymised data is required to ensure that analysis of health care provision can be completed to support the needs of the health profile of the population within the CCG area based on the full analysis of multiple pseudonymised datasets.
Processing for commissioning will be conducted by MedeAnalytics

National identifiers will be removed by NHS Digital (DSCRO) using MedeAnalytics’ Pseudonymisation at Source process, prior to data leaving NHS Digital. By using the MedeAnalytics process, the resulting de-identified data can be linked within the MedeAnalytics system with data from other providers (as specified in this application) using the same process, without the need for identifiable data to flow to MedeAnalytics.

Further, as national identifiers are removed by NHS Digital before transmission, thus together with other approaches rendering the data Anonymous in line with the ICO’s anonymisation code of practice, the resulting, non-identifiable data representing 100% of the commissioner’s records is suitable for General Commissioning and Contract Validation purposes, both of which have been previously approved. As data Is anonymous in context, there is no need to remove records for type 2 objectors, as the records are no longer identifiable when they leave the protected NHS Digital environment.

Where analysis of pseudonymised patient records show that the associated patients could benefit from clinical interventions, GP Practice users who have legitimate relationships with the patients will be able to re-identify the patient records so that they can provide the interventions (direct care).

Yielded Benefits:

Benefits to date are in line with what we expected to achieve at this point in time as described in the previous application. The continued access to this data will enable the CCG to further understand and improve service performance, and thus patient pathway redesign and the patient experience.

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
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.
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.
All of the above lead to improved patient experience through more effective commissioning of services. Users of the same MedeAnalytics service have feedback that:
Showing the number of benchmarked A&E admissions (and A&E attendances in the next analysis) from specific local geographical locations in a heat map, will enable the CCG and providers to direct our finite health and social care (public health) resources more efficiently and effectively.
Users can better understand variation in their system, and make comparisons between populations and organisations in a fair and meaningful way with a greater understanding of what normal is. This will support routine opportunity analyses that they carry out in order to best target resources and best understand which activities have had a genuine benefit, and helped reduce costs to the system.
In addition, the platform provides access to comprehensive supporting information that commissioning organisations such as Clinical Commissioning Groups use to ensure that the services they commission:
• deliver the best outcomes for their patients
• cater for and meet the needs of the population they are responsible for;
• monitor condition prevalence within the population
• identify health inequalities and work with local organisations and agencies to remove them

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
Commissioning
General reporting
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.
Analytics Insights
Reports, charts and dashboards providing insights into:
1. 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
2. Data Quality and Validation measures allowing data quality checks on the submitted data
3. Contract Management and Modelling
4. 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
5. Understanding impacts and interdependency of care services

Update to support application extension:
Outcomes/Benefits have been achieved in line with expectations so expected outputs/benefits for this application remain the same

Processing:

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

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

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

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

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

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

Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.
All access to data is audited.

Before 31/07/2018 -

Invoice Validation – Identifiable - SUS
1. Identifiable SUS Data is obtained from the SUS Repository by North East London Data Services for Commissioners Regional Office (DSCRO).
2. North East London DSCRO then pushes a one-way data flow of data Identifiable at the level of NHS number according to S.251 CAG 7-07(a) and (b)/2013 SUS data into North East London Commissioning Support Unit Transfer Service.
3. North East London Commissioning Support Unit lands the data only.
4. CCG CEfF staff log in to the North East London Commissioning Support Unit Transfer service and download the Invoice Validation data to their CEfF. Once downloaded, CCG staff delete the data from the Transfer Service.
5. 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 national SUS data flow to validate the corresponding record in the backing data flow
b. Backing information is received from providers directly into the CCG CEfF. Once received, it is checked against national NHS and local commissioning policies as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:
i. In line with Payment by Results tariffs
ii. Are in relation to a patient registered with 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.
6. 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

Segregation
Data for this purpose is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CCG CEfF staff are able to access data in the CEfF from the transfer service, and only CCG CEfF staff operate the invoice validation process within the CCG’s CEfF. Data flows directly in to the CEfF from NHS Digital (via the CSU) and from the providers – it does not flow through other processors.

Commissioning
The North East London Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1) SUS
2) Local Provider Flows (received directly from providers)
a. Ambulance
b. Demand for Service
c. Diagnostic Service
d. Emergency Care
e. Experience, Quality and Outcomes
f. Mental Health
g. Other Not Elsewhere Classified
h. Population Data
i. 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 using the Medeanalytics pseudonymisation tool 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) and Diagnostic Imaging data (DIDS) only is securely transferred from the DSCRO to North East London Commissioning Support Unit for landing only.
2) North East London Commissioning Support Unit then pass the processed, Pseudonymised data provided under DSCRO contracts to the CCGs data processor, Medeanalytics International Limited where it is received, stored and processed
3) Records contain no national identifiers, but do contain the following local identifiers: [Local Patient Identifier], [Hospital Provider Spell No], [Unique CDS Identifier], [Attendance Identifier], and [A&E Attendance Number]
4) On arrival at Medeanalytics International Limited, one of the Medeanalytics International Limited operational staff then transfers the data from the secure landing zone to the ETL process. The Extract Transform Load (ETL) process then loads the data into the Medeanalytics International Limited system, where it is linked.
5) Allowed linkage is between the data sets contained within point 1 and the following data that is pseudonymised at source using the Medeanalytics pseudonymisation tool:
o Social Care data
o GP Practice data
o Community data
o Mental Health data
6) Access is fully controlled by Role Based Access Control (RBAC),, signed off by Caldicott Guardians/SIROs.
7) CCGs use the workflow features provided by the Medeanalytics International Limited Contract Validation Module to check recorded activity against contracts, and facilitate contract discussions with providers
8) CCG users use online features of the Medeanalytics International Limited system to produce reports, charts and dashboards to analyse the data for the purposes listed.
9) Pseudonymised 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 with access fully controlled by RBAC, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared.

Segregation
Data is held within the MedeAnalytics system, and is segregated according to contract.
Only MedeAnalytics operational staff (currently 4 individuals operating under full time MedeAnalytics employment contracts) have access to data prior to loading into the main system.
All staff at MedeAnalytics undertake compulsory IG Toolkit training every year.
All MedeAnalytics staff understand their responsibilities with regard to receiving, storage, processing and handling of data, and contractual sanctions that can result in disciplinary actions including dismissal for contraventions are included in employee contracts.
Specific processes are in place to setup new system users, all of which require Caldicott Guardian or SIRO sign-off in order to obtain user identities and passwords. Identities and passwords are restricted to specific subsets of data according to their Roles, so that a CCG user can only see data for their own CCG, and a GP user can only see data for their own GP Practice.
All access to data is managed under Roles-Based Access Controls
Access to data is provided through the MedeAnalytics front end interfaces, for on-line access; while it is reasonable and allowable for users to export the results displayed in reports, charts and dashboards, so that the results can be used in board presentations, reports and other management documents, bulk export of underlying linked data sets is not possible.
All accesses are audited
CCG staff are only able to access data pertinent to their own CCG
GP Practice staff are only able to access data for patients registered to their own practice
Re-identification (managed under RBAC) requires an additional step to access re-identification keys held by an independent third party key management service (operated by BMS) that has no access to the data. Disabling a user’s account in the key management system immediately removes the ability of that user to access re-identification keys.
Each Re-identification requires a different key, so inappropriate retention of keys (which is neither allowed, nor easy to accomplish by design) will not result in compromise of data
Only GP Practice users are able to re-identify patients and only when they have a legitimate reason and a legal right to re-identify have access to encrypted data, and can only access data to which they have rights under RBAC (which is CG/SIRO approved– within the CCG)
All data providers for a particular region (according to contract) are issued with encryption keys that ensure data for their region can only be linked to data from other providers for the same region. This means that data for two different regional customers cannot be accidentally mixed.

Commissioning – Pseudonymised – Local Flows
Management of services for non-contracted activities
The North East London Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1) Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Diagnostic Service
e. Primary Care Services
Data quality management and pseudonymisation is completed within the DSCRO is then disseminated as follows:
1. North East London DSCRO then remove national identifiers to Pseudonymise the data
2. CCG staff then download the processed, Pseudonymised data from the North East London CSU transfer service, and will then delete the data from the transfer service. The CCG analyse the data to see patient journeys for pathways or service design, re-design and commissioning.
3. Aggregation of required data for CCG management use will be completed by the CCG.
4. 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 Agreements
5. CCG staff then log in to the CSU transfer service and download the data to the CCG’s systems outside the CEfF. CSU staff then delete the data from the transfer service.

From 01/08/2018 -

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 the 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.
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

Segregation
Data for this purpose is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CCG CEfF staff are able to access data in the CEfF from the transfer service, and only CCG CEfF staff operate the invoice validation process within the CCG’s CEfF. Data flows directly in to the CEfF from NHS Digital and from the providers – it does not flow through other processors.

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. Ambulance
b. Demand for Service
c. Diagnostic Service
d. Emergency Care
e. Experience, Quality and Outcomes
f. Mental Health
g. Other Not Elsewhere Classified
h. Population Data
i. 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 using the Medeanalytics pseudonymisation tool 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) and National Cancer Waiting Times Monitoring Data Set (CWT) only is securely transferred from the DSCRO to Medeanalytics
2) Records contain no national identifiers, but do contain the following local identifiers: [Local Patient Identifier], [Hospital Provider Spell No], [Unique CDS Identifier], [Attendance Identifier], and [A&E Attendance Number]
3) On arrival at Medeanalytics International Limited, one of the Medeanalytics International Limited operational staff then transfers the data from the secure landing zone to the ETL process. The Extract Transform Load (ETL) process then loads the data into the Medeanalytics International Limited system, where it is linked.
4) Allowed linkage is between the data sets contained within point 1 and the following data that is pseudonymised at source using the Medeanalytics pseudonymisation tool:
o Social Care data
o GP Practice data
o Community data
o Mental Health data
5) Medeanalytics 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

6) Access is fully controlled by Role Based Access Control (RBAC),, signed off by Caldicott Guardians/SIROs.
7) CCGs use the workflow features provided by the Medeanalytics International Limited Contract Validation Module to check recorded activity against contracts, and facilitate contract discussions with providers
8) CCG users use online features of the Medeanalytics International Limited system to produce reports, charts and dashboards to analyse the data for the purposes listed.
9) Aggregation of required data for CCG management use will be completed by Medeanalytics or the CCG as instructed by the CCG.
10) Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared as set out wi
thin NHS Digital guidance applicable to each data set.

Segregation
Data is held within the MedeAnalytics system, and is segregated according to contract.
Only MedeAnalytics operational staff (currently 4 individuals operating under full time MedeAnalytics employment contracts) have access to data prior to loading into the main system.
All staff at MedeAnalytics undertake compulsory IG Toolkit training every year.
All MedeAnalytics staff understand their responsibilities with regard to receiving, storage, processing and handling of data, and contractual sanctions that can result in disciplinary actions including dismissal for contraventions are included in employee contracts.
Specific processes are in place to setup new system users, all of which require Caldicott Guardian or SIRO sign-off in order to obtain user identities and passwords. Identities and passwords are restricted to specific subsets of data according to their Roles, so that a CCG user can only see data for their own CCG, and a GP user can only see data for their own GP Practice.
All access to data is managed under Roles-Based Access Controls
Access to data is provided through the MedeAnalytics front end interfaces, for on-line access; while it is reasonable and allowable for users to export the results displayed in reports, charts and dashboards, so that the results can be used in board presentations, reports and other management documents, bulk export of underlying linked data sets is not possible.
All accesses are audited
CCG staff are only able to access data pertinent to their own CCG
GP Practice staff are only able to access data for patients registered to their own practice
Re-identification (managed under RBAC) requires an additional step to access re-identification keys held by an independent third party key management service (operated by BMS) that has no access to the data. Disabling a user’s account in the key management system immediately removes the ability of that user to access re-identification keys.
Each Re-identification requires a different key, so inappropriate retention of keys (which is neither allowed, nor easy to accomplish by design) will not result in compromise of data
Only GP Practice users are able to re-identify patients and only when they have a legitimate reason and a legal right to re-identify have access to encrypted data, and can only access data to which they have rights under RBAC (which is CG/SIRO approved– within the CCG)
All data providers for a particular region (according to contract) are issued with encryption keys that ensure data for their region can only be linked to data from other providers for the same region. This means that data for two different regional customers cannot be accidentally mixed.

Commissioning – Pseudonymised – Local Flows
Management of services for non-contracted activities
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1) Local Provider Flows (received directly from providers)
a. Acute
b. Ambulance
c. Community
d. Diagnostic Service
e. Primary Care Services
Data quality management and pseudonymisation is completed within the DSCRO is then disseminated as follows:
1. DSCRO then remove national identifiers to Pseudonymise the data
2. CCG staff then download the processed, Pseudonymised data from the DSCRO. The CCG analyse the data to see patient journeys for pathways or service design, re-design and commissioning.
3. Aggregation of required data for CCG management use will be completed by the CCG.
4. 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.