NHS Digital Data Release Register - reformatted
NHS Humber And North Yorkshire Icb - 02y projects
- DSfC - Humber, Coast and Vale ICS - Comm
- DSfC - NHS East Riding of Yorkshire CCG, IV RS Comm with GP/social/consent linkage
- GDPPR COVID-19 CCG - Pseudo
- DSfC - NHS East Riding of Yorkshire CCG - STP - Comm
170 data files in total were disseminated unsafely (information about files used safely is missing for TRE/"system access" projects).
DSfC - Humber, Coast and Vale ICS - Comm — DARS-NIC-523441-B9W2H
Type of data: information not disclosed for TRE projects
Opt outs honoured: Anonymised - ICO Code Compliant (Does not include the flow of confidential data)
Legal basis: Health and Social Care Act 2012 - s261 - 'Other dissemination of information'
Purposes: No (Sub ICB Location)
Sensitive: Sensitive
When:DSA runs 2021-08-01 — 2024-07-31
Access method: Frequent Adhoc Flow
Data-controller type: NHS HUMBER AND NORTH YORKSHIRE ICB - 02Y, NHS HUMBER AND NORTH YORKSHIRE ICB - 03F, NHS HUMBER AND NORTH YORKSHIRE ICB - 03H, NHS HUMBER AND NORTH YORKSHIRE ICB - 03K, NHS HUMBER AND NORTH YORKSHIRE ICB - 03Q, NHS HUMBER AND NORTH YORKSHIRE ICB - 42D
Sublicensing allowed: No
Datasets:
- Acute-Local Provider Flows
- Adult Social Care
- Ambulance-Local Provider Flows
- Children and Young People Health
- Civil Registration - Births
- Civil Registration - Deaths
- Community Services Data Set
- Community-Local Provider Flows
- Demand for Service-Local Provider Flows
- Diagnostic Imaging Dataset
- Diagnostic Services-Local Provider Flows
- Emergency Care-Local Provider Flows
- e-Referral Service for Commissioning
- Experience, Quality and Outcomes-Local Provider Flows
- Improving Access to Psychological Therapies Data Set_v1.5
- Maternity Services Data Set
- Medicines dispensed in Primary Care (NHSBSA data)
- Mental Health and Learning Disabilities Data Set
- Mental Health Minimum Data Set
- Mental Health Services Data Set
- Mental Health-Local Provider Flows
- National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
- National Diabetes Audit
- Other Not Elsewhere Classified (NEC)-Local Provider Flows
- Patient Reported Outcome Measures
- Personal Demographic Service
- Population Data-Local Provider Flows
- Primary Care Services-Local Provider Flows
- Public Health and Screening Services-Local Provider Flows
- Summary Hospital-level Mortality Indicator
- SUS for Commissioners
- 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)
Expected Benefits:
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.
29. Developing, through evaluation of person-level data, more effective prevention strategies and interventions across a pathway or care setting involving adult social care
30. Designing and implementing new payment models across health and adult social care
31. Understanding current and future population needs and resource utilisation for local strategic planning and commissioning purposes including for health, social care and public health needs.
City Health Care Partnership
1. Enable joint working between CHCP, the CCG and Primary Care Networks/ General Practice
2. Prevention of worse outcomes for patients
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.
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. CCGs 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 patients high numbers of different medications (polypharmacy)
29. Monitoring, at a population level, particular cohorts of service users and designing analytical models which support more effective interventions in health and adult social care
30. Monitoring service and integrated care outcomes across a pathway or care setting involving adult social care
City Health Care Partnership (CHCP)
CHCP have a legitimate relationship with patients as providers of health and care services. CHCP will use the pseudonymised data to identify a cohort of patients for treatment or intervention.
The identified cohort will be used to support discussions with PCNs/GPs to agree an appropriate intervention.
In order to implement the agreed intervention CHCP will need to have NHS number.
CHCP will obtain this information by using the "re-identify patients" option in RAIDR, after completing the systems checks to confirm that the access is to provide direct patient care.
The process used to re-identify patients in the supporting documents to this application.
CHCP will also use the NHS number to support discussions with GPS on agreeing an appropriate care plan for the patient.
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:
There is no requirement for the analytical teams to re-identify patients, but in the development of cohorts of patients considered to be at risk, the data controllers may need the facility to provide identifiable results back to direct healthcare professionals or local authority direct care staff only for the purpose of direct care. All re-id requests will be processed and authorised by the DSCRO on a case by case basis. National data opt outs are not applied in these cases as they are for the purposes of direct care which follows the legal basis of implied consent.
An example of a request for the re-id of patients for direct care may be;
A&E High Attendance usage
The CCG can filter data to show for example the number of A&E attendances in a given period for each patient. The CCG can then flag to the relevant GP of the patient any patients that require intervention. An outcome of this is earlier intervention in the patient(s) care thus potentially reducing future costs and minimising future risk.
Polypharmacy re-IDs
CCG's can request re-ID of a list of patients to be sent to the relevant GP with a high number of medications (ingredient count) and review the medication for these patients. This can help address the risk of polypharmacy which is recognised as an adverse risk factor for patient safety. A by-product of such reviews may be to reduce costs of medication.
The Re-identification process for direct care is as follows:
1. The CCG identifies a patient cohort (typically small numbers) to be re-identified for the purpose of direct care.
2. The CCG sends a re-id request to the DSCRO. This may be done through the CCG or CSUs Business Intelligence (BI) Tool, or through a manual form.
3. The DSCRO (either through an automated system or manual checking in line with the request) assesses as to whether the request passes the specified re-identification process checks. Checks include if the requester is authorised to access identifiable data, if the number of patients in the cohort is appropriate, and that the request does not seem inappropriate or outside of expected parameters, including for example around timings and the requestors relationship with patients in the data
4. If successful/approved, the DSCRO re-identifies the relevant data item(s) for the appropriate patients and returns the identifiable fields to Health or care professional(s) with a legitimate relationship to the patient. The CCG does not see the identifiable record.
5. DSCROs retain an audit trail of all re-id requests
6. National Data opt outs are not applied for the purpose of direct care
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 NHS North Lincolnshire CCG, NHS North East Lincolnshire CCG, NHS East Riding of Yorkshire, NHS Hull CCG, NHS North Yorkshire CCG or NHS Vale of York CCGs' regions (including historical activity where the patient was previously registered or resident in another commissioner).
and/or
Patients treated by a provider where NHS North Lincolnshire CCG, NHS North East Lincolnshire CCG, NHS East Riding of Yorkshire, NHS Hull CCG, NHS North Yorkshire CCG or NHS Vale of York 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 North Lincolnshire CCG, NHS North East Lincolnshire CCG, NHS East Riding of Yorkshire, NHS Hull CCG, NHS North Yorkshire CCG and NHS Vale of York CCGs' - this is only for commissioning and relates to both national and local flows.
In addition to the dissemination of Cancer Waiting Times Data via the DSCRO, the CCGs are able to access reports held within the CWT system in NHS Digital directly. Access within the CCG is limited to those with a need to process the data for the purposes described in this agreement.
A CCG user will be able to access the provider extracts from the portal for any provider where at least 1 patient for whom they are the registered CCG for that individuals GP practice appears in that setting
Although a CCG user may have access to pseudonymised patient information not related to that CCG, users should only process and analyse data for which they have a legitimate relationship (as described within Data Minimisation).
Microsoft Limited provide Cloud Services for NHS North of England Commissioning Support Unit and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data
N3i Limited and North Lincolnshire Council and North East Lincolnshire Council 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.
City Health Care Partnership are providers of a range of health and care services across the local community. They are listed as a processor to enable access to the BI RAIDR Dashboards pseudonymised secondary care community data in order to facilitate joint working between CHCP the CCG and PCNs/General Practice.
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.
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)
20. Adult Social Care Data
Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
Data Processor 1 NHS 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 Peoples 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), Medicines Dispensed in Primary Care (NHSBSA Data) and Adult Social Care data only is securely transferred from the DSCRO to North of England Commissioning Support Unit.
2. North of England Commissioning Support Unit also receive pseudonymised GP Data and Social Care data. (See i ix for detail)
3. North of England Commissioning Support Unit add derived fields and link data. Data is stored on a server held within North of England Commissioning Support Unit.
4. North of England Commissioning Support Unit 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
5. North of England Commissioning Support Unit also apply a risk stratification algorithm to pseudonymised SUS+, Local Provider flow and GP data only.
6. The processed pseudonymised data is then transferred to the CCG
7. Aggregation of required data for CCG management use will be completed by North of England Commissioning Support Unit as instructed by the CCGs.
8. Patient level data will not be shared outside of the Data Processor/Controller and will only be shared within the Data Processors 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.
9. The CCG securely transfer Pseudonymised data back to the provider to:
a) confirm how patients are reported in SUS, and how the commissioner can reliably group these patients into categories for points of delivery;
b) allow for granular data validation whereby a commissioner may query the SUS record, and need to pass it back to the provider for checking; and
c) to allow the provider to undertake further analysis of a cohort of their patients as requested and specified by the
commissioner.
The data transferred to the provider is only that which relates directly to the data previously uploaded by that particular provider.
All access to the North of England Commissioning Support Unit server is managed via Role Based Access Controls.
North of England Commissioning Support Unit have individual data processing agreements in place with GPs, Local Authorities and the CCGs, to pseudonymise data. Acting on their behalf, North of England Commissioning Support Unit pseudonymises the data as follows:
i. Identifiable GP and Social Care data is submitted to North of England Commissioning Support Unit.
ii. The data lands in a ring-fenced area.
iii. North of England Commissioning Support Unit has access to a pseudonymisation tool. North of England Commissioning Support Unit requests an organisation specific pseudonymisation key from the DSCRO. The key can only be used once. The key is specific to the individual request and the organisation it is being requested for.
iv. The data is then pseudonymised using the organisation specific pseudonymisation tool and DSCRO issued key. The identifiable data is then deleted from the ring-fenced area.
v. To enable linkage to data listed in point 1, North of England Commissioning Support Unit make a request to the DSCRO.
vi. The DSCRO then send a mapping table to North of England Commissioning Support Unit.
vii. A black box uses the mapping table to overwrite the organisation specific pseudonym with the DSCRO pseudonym to enable linkage to NHS Digital released products (under this agreement).
viii. The mapping table if then deleted.
ix. In addition, for social care data only: Social Care organisations have access to the pseudonymisation tool and can request an organisation specific pseudonymisation key from the DSCRO. The key can only be used once and is specific to that date. The organisation then submits the pseudonymised social care data to North of England Commissioning Support Unit. The data then follows from point v.
Data Processor 2 - City Health Care Partnership
1. GP Data, Social care data, Pseudonymised SUS+, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young Peoples 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), Medicines Dispensed in Primary Care (NHSBSA Data) and Adult Social Care data only is securely transferred from the DSCRO to City Health Care Partnership.
2. City Health Care Partnership will analyse the data and select a cohort of patients who require a particular intervention to their care.
3. City Health Care Partnership will then re-identify patients requiring intervention for direct care purposes through the BI tool provided by North of England Commissioning Support Unit.
4. City Health Care Partnership will then work with the GP for the identified patients to develop care plans to improve their care and lower risk of worse outcomes.
5. Patient level will only be shared outside of City Health Care Partnership where it is for the purpose of direct care with those health professionals who have a legitimate relationship with the patient and a legitimate reason to access the data.
DSfC - NHS East Riding of Yorkshire CCG, IV RS Comm with GP/social/consent linkage — DARS-NIC-90658-F0W4R
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, Mixed, Mixture of confidential data flow(s) with consent and flow(s) with support under 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), Section 251 NHS Act 2006)
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(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 2018-11-01 — 2021-10-31 2018.06 — 2021.05.
Access method: Frequent adhoc flow, Frequent Adhoc Flow, One-Off
Data-controller type: NHS EAST RIDING OF YORKSHIRE CCG, NHS HUMBER AND NORTH YORKSHIRE ICB - 02Y
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
- 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)
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 North of England CSU.
The CCG are advised by North of England CSU whether payment for invoices can be made or not.
Risk Stratification
Risk stratification is a tool for identifying and predicting which patients are at high risk or are likely to be at high risk and prioritising the management of their care in order to prevent worse outcomes.
To conduct risk stratification Secondary User Services (SUS+) data, identifiable at the level of NHS number is linked with Primary Care data (from GPs) and an algorithm is applied to produce risk scores. Risk Stratification provides focus for future demands by enabling commissioners to prepare plans for patients. Commissioners can then prepare plans for patients who may require high levels of care. Risk Stratification also enables General Practitioners (GPs) to better target intervention in Primary Care.
The legal basis for this to occur is under Section 251 of NHS Act 2006 (CAG 7-04(a)).
Risk Stratification will be conducted by the CCG
Commissioning
To use pseudonymised data to provide intelligence to support the commissioning of health services. The data (containing both clinical and financial information) is analysed so that health care provision can be planned to support the needs of the population within the CCG area.
The CCGs commission services from a range of providers covering a wide array of services. Each of the data flow categories requested supports the commissioned activity of one or more providers.
The following pseudonymised datasets are required to provide intelligence to support commissioning of health services:
- Secondary Uses Service (SUS+)
- Local Provider Flows
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
- Mental Health Minimum Data Set (MHMDS)
- Mental Health Learning Disability Data Set (MHLDDS)
- Mental Health Services Data Set (MHSDS)
- Maternity Services Data Set (MSDS)
- Improving Access to Psychological Therapy (IAPT)
- Child and Young People Health Service (CYPHS)
- Diagnostic Imaging Data Set (DIDS)
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 North of England Commissioning Support Unit and eMBED Health Consortium.
Yielded Benefits:
Expected Benefits:
Invoice Validation
1. Financial validation of activity
2. CCG Budget control
3. Commissioning and performance management
4. Meeting commissioning objectives without compromising patient confidentiality
5. The avoidance of misappropriation of public funds to ensure the ongoing delivery of patient care
Risk Stratification
Risk stratification promotes improved case management in primary care and will lead to the following benefits being realised:
1. Improved planning by better understanding patient flows through the healthcare system, thus allowing commissioners to design appropriate pathways to improve patient flow and allowing commissioners to identify priorities and identify plans to address these.
2. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services thus allowing early intervention.
3. Improved access to services by identifying which services may be in demand but have poor access, and from this identify areas where improvement is required.
4. Supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework by allowing for more targeted intervention in primary care.
5. Better understanding of local population characteristics through analysis of their health and healthcare outcomes
All of the above lead to improved patient experience through more effective commissioning of services.
Commissioning
1. Supporting Quality Innovation Productivity and Prevention (QIPP) to review demand management, integrated care and pathways.
a. Analysis to support full business cases.
b. Develop business models.
c. Monitor In year projects.
2. Supporting Joint Strategic Needs Assessment (JSNA) for specific disease types.
3. Health economic modelling using:
a. Analysis on provider performance against 18 weeks wait targets.
b. Learning from and predicting likely patient pathways for certain conditions, in order to influence early interventions and other treatments for patients.
c. Analysis of outcome measures for differential treatments, accounting for the full patient pathway.
d. Analysis to understand emergency care and linking A&E and Emergency Urgent Care Flows (EUCC).
4. Commissioning cycle support for grouping and re-costing previous activity.
5. Enables monitoring of:
a. CCG outcome indicators.
b. Financial and Non-financial validation of activity.
c. Successful delivery of integrated care within the CCG.
d. Checking frequent or multiple attendances to improve early intervention and avoid admissions.
e. Case management.
f. Care service planning.
g. Commissioning and performance management.
h. List size verification by GP practices.
i. Understanding the care of patients in nursing homes.
6. Feedback to NHS service providers on data quality at an aggregate and individual record level – only on data initially provided by the service providers.
7. Improved planning by better understanding patient flows through the healthcare system, thus allowing commissioners to design appropriate pathways to improve patient flow and allowing commissioners to identify priorities and identify plans to address these.
8. Improved quality of services through reduced emergency readmissions, especially avoidable emergency admissions. This is achieved through mapping of frequent users of emergency services and early intervention of appropriate care.
9. Improved access to services by identifying which services may be in demand but have poor access, and from this identify areas where improvement is required.
10. Potentially reduced premature mortality by more targeted intervention in primary care, which supports the commissioner to meets its requirement to reduce premature mortality in line with the CCG Outcome Framework.
11. Better understanding of the health of and the variations in health outcomes within the population to help understand local population characteristics.
12. Better understanding of contract requirements, contract execution, and required services for management of existing contracts, and to assist with identification and planning of future contracts
13. Insights into patient outcomes, and identification of the possible efficacy of outcomes-based contracting opportunities.
Outputs:
Invoice Validation
1. Addressing poor data quality issues
2. Production of reports for business intelligence
3. Budget reporting
4. Validation of invoices for non-contracted events
Risk Stratification
1. As part of the risk stratification processing activity detailed above, GPs have access to the risk stratification tool which highlights patients for whom the GP is responsible and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
2. Output from the risk stratification tool will provide aggregate reporting of number and percentage of population found to be at risk.
3. Record level output will be available for commissioners (of the CCG), pseudonymised at patient level.
4. GP Practices will be able to view the risk scores for individual patients with the ability to display the underlying SUS+ data for the individual patients when it is required for direct care purposes by someone who has a legitimate relationship with the patient.
5. The CCG will be able to target specific patient groups and enable clinicians with the duty of care for the patient to offer appropriate interventions. The CCG will also be able to:
o Stratify populations based on: disease profiles; conditions currently being treated; current service use; pharmacy use and risk of future overall cost
o Plan work for commissioning services and contracts
o Set up capitated budgets
o Identify health determinants of risk of admission to hospital, or other adverse care outcomes.
Commissioning
1. Commissioner reporting:
a. Summary by provider view - plan & actuals year to date (YTD).
b. Summary by Patient Outcome Data (POD) view - plan & actuals YTD.
c. Summary by provider view - activity & finance variance by POD.
d. Planned care by provider view - activity & finance plan & actuals YTD.
e. Planned care by POD view - activity plan & actuals YTD.
f. Provider reporting.
g. Statutory returns.
h. Statutory returns - monthly activity return.
i. Statutory returns - quarterly activity return.
j. Delayed discharges.
k. Quality & performance referral to treatment reporting.
2. Readmissions analysis.
3. Production of aggregate reports for CCG Business Intelligence.
4. Production of project / programme level dashboards.
5. Monitoring of acute / community / mental health quality matrix.
6. Clinical coding reviews / audits.
7. Budget reporting down to individual GP Practice level.
8. GP Practice level dashboard reports include high flyers.
9. Comparators of CCG performance with similar CCGs as set out by a specific range of care quality and performance measures detailed activity and cost reports
10. Data Quality and Validation measures allowing data quality checks on the submitted data
11. Contract Management and Modelling
12. Patient Stratification, such as:
o Patients at highest risk of admission
o Most expensive patients (top 15%)
o Frail and elderly
o Patients that are currently in hospital
o Patients with most referrals to secondary care
o Patients with most emergency activity
o Patients with most expensive prescriptions
o Patients recently moving from one care setting to another
i. Discharged from hospital
ii. Discharged from community
Processing:
Data must only be used as stipulated within this Data Sharing Agreement.
Data Processors must only act upon specific instructions from the Data Controller.
Data can only be stored at the addresses listed under storage addresses.
The Data Controller and any Data Processor will only have access to records of patients of residence and registration within the CCG.
Patient level data will not be shared outside of the CCG unless it is for the purpose of Direct Care, where it may be shared only with those health professionals who have a legitimate relationship with the patient and a legitimate reason to access the data.
All access to data is managed under Roles-Based Access Controls
No patient level data will be linked other than as specifically detailed within this agreement. Data will only be shared with those parties listed and will only be used for the purposes laid out in the application/agreement. The data to be released from NHS Digital will not be national data, but only that data relating to the specific locality and that data required by the applicant.
NHS Digital reminds all organisations party to this agreement of the need to comply with the Data Sharing Framework Contract requirements, including those regarding the use (and purposes of that use) by “Personnel” (as defined within the Data Sharing Framework Contract ie: employees, agents and contractors of the Data Recipient who may have access to that data)
The DSCRO (part of NHS Digital) will apply Type 2 objections before any identifiable data leaves the DSCRO.
CCGs should work with general practices within their CCG to help them fulfil data controller responsibilities regarding flow of identifiable data into risk stratification tools.
Segregation
Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.
All access to data is auditable by NHS Digital.
Data for the purpose of Invoice Validation is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CEfF staff are able to access data in the CEfF and only CEfF staff operate the invoice validation process within the CEfF. Data flows directly in to the CEfF from the DSCRO and from the providers – it does not flow through any other processors.
Invoice Validation
Data Processor 1- North of England CSU
1. Identifiable SUS+ Data is obtained from the SUS+ Repository to the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO pushes a one-way data flow of SUS+ data into the Controlled Environment for Finance (CEfF) in the CSU.
3. The CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Validating that the Clinical Commissioning Group is responsible for payment for the care of the individual by using SUS+ and/or backing flow data.
b. Once the backing information is received, this will be checked against national NHS and local commissioning policies as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:
i. In line with Payment by Results tariffs
ii. are in relation to a patient registered with a CCG GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance.
4. The CCG are notified that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between North of England CSU CEfF team and the provider meaning that no identifiable data needs to be sent to the CCG. The CCG only receives notification to pay and management reporting detailing the total quantum of invoices received pending, processed etc.
Risk Stratification
1. Identifiable SUS+ data is obtained from the SUS Repository to the Data Services for Commissioners Regional Office (DSCRO).
2. Data quality management and standardisation of data is completed by the DSCRO and the data identifiable at the level of NHS number is transferred securely to the CCG, who hold the SUS+ data within the secure Data Centre on N3.
3. Identifiable GP Data is securely sent from the GP system to the CCG.
4. SUS+ data is linked to GP data in the risk stratification tool by the data processor.
5. As part of the risk stratification processing activity, GPs have access to the risk stratification tool within the data processor, which highlights patients with whom the GP has a legitimate relationship and have been classed as at risk. The only identifier available to GPs is the NHS numbers of their own patients. Any further identification of the patients will be completed by the GP on their own systems.
6. Once the CCG has completed the processing, access is available through the online system via a secure N3 connection to access the data pseudonymised at patient level / aggregate with small number suppression / aggregate without small number suppression / anonymous reports. (confirm which).
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. Diagnostic Imaging Data Set (DIDS)
Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
Data Processor 1 – 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) and Diagnostic Imaging data (DIDS) only is securely transferred from the DSCRO to North of England Commissioning Support Unit.
2. North of England Commissioning Support Unit then pass the processed, pseudonymised data to both eMBED Health Consortium and the CCG.
Data Processor 2 - eMBED Health Consortium
3. eMBED Health Consortium 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
4. Allowed linkage is between the data sets contained within point 1.
5. eMBED Health Consortium then pass the processed, pseudonymised and linked data to the CCG.
6. The CCG analyse the data received from eMBED Health Consortium and North of England Commissioning Support Unit to see patient journeys for pathways or service design, re-design and de-commissioning.
7. Aggregation of required data for CCG management use will be completed by North of England Commissioning Support Unit, eMBED Health Consortium or the CCG as instructed by the CCG.
8. 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.
9. The CCG securely transfer Pseudonymised data back to the provider to:
a) confirm how patients are reported in SUS, and how the commissioner can reliably group these patients into categories for points of delivery;
b) allow for granular data validation whereby a commissioner may query the SUS record, and need to pass it back to the provider for checking; and
c) to allow the provider to undertake further analysis of a cohort of their patients as requested and specified by the commissioner.
The data transferred to the provider is only that which relates directly to the data previously uploaded by that particular provider.
GDPPR COVID-19 CCG - Pseudo — DARS-NIC-404700-Z7J3X
Type of data: information not disclosed for TRE projects
Opt outs honoured: No - Statutory exemption to flow confidential data without consent, Anonymised - ICO Code Compliant (Statutory exemption to flow confidential data without consent)
Legal basis: CV19: Regulation 3 (4) of the Health Service (Control of Patient Information) Regulations 2002, CV19: Regulation 3 (4) of the Health Service (Control of Patient Information) Regulations 2002; Health and Social Care Act 2012 - s261(5)(d)
Purposes: No (Clinical Commissioning Group (CCG), Sub ICB Location)
Sensitive: Sensitive
When:DSA runs 2020-09-23 — 2021-03-31 2021.01 — 2021.05.
Access method: One-Off, Frequent Adhoc Flow
Data-controller type: NHS EAST RIDING OF YORKSHIRE CCG, NHS HULL CCG, NHS HUMBER AND NORTH YORKSHIRE ICB - 02Y, NHS HUMBER AND NORTH YORKSHIRE ICB - 03F
Sublicensing allowed: No
Datasets:
- GPES Data for Pandemic Planning and Research (COVID-19)
- COVID-19 General Practice Extraction Service (GPES) Data for Pandemic Planning and Research (GDPPR)
Objectives:
NHS Digital has been provided with the necessary powers to support the Secretary of State’s response to COVID-19 under the COVID-19 Public Health Directions 2020 (COVID-19 Directions) and support various COVID-19 purposes, the data shared under this agreement can be used for these specified purposes except where they would require the reidentification of individuals.
GPES data for pandemic planning and research (GDPPR COVID 19)
To support the response to the outbreak, NHS Digital has been legally directed to collect and analyse healthcare information about patients from their GP record for the duration of the COVID-19 emergency period under the COVID-19 Directions.
The data which NHS Digital has collected and is providing under this agreement includes coded health data, which is held in a patient’s GP record, such as details of:
• diagnoses and findings
• medications and other prescribed items
• investigations, tests and results
• treatments and outcomes
• vaccinations and immunisations
Details of any sensitive SNOMED codes included in the GDPPR data set can be found in the Reference Data and GDPPR COVID 19 user guides hosted on the NHS Digital website. SNOMED codes are included in GDPPR data.
There are no free text record entries in the data.
The Controller will use the pseudonymised GDPPR COVID 19 data to provide intelligence to support their local response to the COVID-19 emergency. The data is analysed so that health care provision can be planned to support the needs of the population within the CCG area for the COVID-19 purposes.
Such uses of the data include but are not limited to:
• Analysis of missed appointments - Analysis of local missed/delayed referrals due to the COVID-19 crisis to estimate the potential impact and to estimate when ‘normal’ health and care services may resume, linked to Paragraph 2.2.3 of the COVID-19 Directions.
• Patient risk stratification and predictive modelling - to highlight patients at risk of requiring hospital admission due to COVID-19, computed using algorithms executed against linked de-identified data, and identification of future service delivery models linked to Paragraph 2.2.2 of the COVID-19 Directions. As with all risk stratification, this would lead to the identification of the characteristics of a cohort that could subsequently, and separately, be used to identify individuals for intervention. However the identification of individuals will not be done as part of this data sharing agreement, and the data shared under this agreement will not be reidentified.
• Resource Allocation - In order to assess system wide impact of COVID-19, the GDPPR COVID 19 data will allow reallocation of resources to the worst hit localities using their expertise in scenario planning, clinical impact and assessment of workforce needs, linked to Paragraph 2.2.4 of the COVID-19 Directions:
The data may only be linked by the Data Controller or their respective Data Processor, to other pseudonymised datasets which it holds under a current data sharing agreement only where such data is provided for the purposes of general commissioning by NHS Digital. The Health Service Control of Patient Information Regulations (COPI) will also apply to any data linked to the GDPPR data.
The linked data may only be used for purposes stipulated within this agreement and may only be held and used whilst both data sharing agreements are live and in date. Using the linked data for any other purposes, including non-COVID-19 purposes would be considered a breach of this agreement. Reidentification of individuals is not permitted under this DSA.
LEGAL BASIS FOR PROCESSING DATA:
Legal Basis for NHS Digital to Disseminate the Data:
NHS Digital is able to disseminate data with the Recipients for the agreed purposes under a notice issued to NHS Digital by the Secretary of State for Health and Social Care under Regulation 3(4) of the Health Service Control of Patient Information Regulations (COPI) dated 17 March 2020 (the NHSD COPI Notice).
The Recipients are health organisations covered by Regulation 3(3) of COPI and the agreed purposes (paragraphs 2.2.2-2.2.4 of the COVID-19 Directions, as stated below in section 5a) for which the disseminated data is being shared are covered by Regulation 3(1) of COPI.
Under the Health and Social Care Act, NHS Digital is relying on section 261(5)(d) – necessary or expedient to share the disseminated data with the Recipients for the agreed purposes.
Legal Basis for Processing:
The Recipients are able to receive and process the disseminated data under a notice issued to the Recipients by the Secretary of State for Health and Social Care under Regulation 3(4) of COPI dated 20th March (the Recipient COPI Notice section 2).
The Secretary of State has issued notices under the Health Service Control of Patient Information Regulations 2002 requiring the following organisations to process information:
Health organisations
“Health Organisations” defined below under Regulation 3(3) of COPI includes CCGs for the reasons explained below. These are clinically led statutory NHS bodies responsible for the planning and commissioning of health care services for their local area
The Secretary of State for Health and Social Care has issued NHS Digital with a Notice under Regulation 3(4) of the National Health Service (Control of Patient Information Regulations) 2002 (COPI) to require NHS Digital to share confidential patient information with organisations permitted to process confidential information under Regulation 3(3) of COPI. These include:
• persons employed or engaged for the purposes of the health service
Under Section 26 of the Health and Social Care Act 2012, CCG’s have a duty to provide and manage health services for the population.
Regulation 7 of COPI includes certain limitations. The request has considered these limitations, considering data minimisation, access controls and technical and organisational measures.
Under GDPR, the Recipients can rely on Article 6(1)(c) – Legal Obligation to receive and process the Disclosed Data from NHS Digital for the Agreed Purposes under the Recipient COPI Notice. As this is health information and therefore special category personal data the Recipients can also rely on Article 9(2)(h) – preventative or occupational medicine and para 6 of Schedule 1 DPA – statutory purpose.
Expected Benefits:
• Manage demand and capacity
• Reallocation of resources
• Bring in additional workforce support
• Assists commissioners to make better decisions to support patients
• Identifying COVID-19 trends and risks to public health
• Enables CCGs to provide guidance and develop policies to respond to the outbreak
• Controlling and helping to prevent the spread of the virus
Outputs:
• Operational planning to predict likely demand on primary, community and acute service for vulnerable patients due to the impact of COVID-19
• Analysis of resource allocation
• Investigating and monitoring the effects of COVID-19
• Patient Stratification in relation to COVID-19, such as:
o Patients at highest risk of admission
o Frail and elderly
o Patients that are currently in hospital
o Patients with prescriptions related to COVID-19
o Patients recently Discharged from hospital
For avoidance of doubt these are pseudonymised patient cohorts, not identifiable.
Processing:
PROCESSING CONDITIONS:
Data must only be used for the purposes stipulated within this Data Sharing Agreement. Any additional disclosure / publication will require further approval from NHS Digital.
Data Processors must only act upon specific instructions from the Data Controller.
All access to data is managed under Role-Based Access Controls. Users can only access data authorised by their role and the tasks that they are required to undertake.
Patient level data will not be linked other than as specifically detailed within this Data Sharing Agreement.
NHS Digital reminds all organisations party to this agreement of the need to comply with the Data Sharing Framework Contract requirements, including those regarding the use (and purposes of that use) by “Personnel” (as defined within the Data Sharing Framework Contract i.e.: employees, agents and contractors of the Data Recipient who may have access to that data).
The Recipients will take all required security measures to protect the disseminated data and they will not generate copies of their cuts of the disseminated data unless this is strictly necessary. Where this is necessary, the Recipients will keep a log of all copies of the disseminated data and who is controlling them and ensure these are updated and destroyed securely.
Onward sharing of patient level data is not permitted under this agreement. Only aggregated reports with small number suppression can be shared externally.
The data disseminated will only be used for COVID-19 GDPPR purposes as described in this DSA, any other purpose is excluded.
SEGREGATION:
Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.
AUDIT
All access to data is auditable by NHS Digital in accordance with the Data Sharing Framework Contract and NHS Digital terms.
Under the Local Audit and Accountability Act 2014, section 35, Secretary of State has power to audit all data that has flowed, including under COPI.
DATA MINIMISATION:
Data Minimisation in relation to the data sets listed within the application are listed below:
• Patients who are normally registered and/or resident within the CCG region (including historical activity where the patient was previously registered or resident in another commissioner area).
and/or
• Patients treated by a provider where the CCG is the host/co-ordinating commissioner and/or has the primary responsibility for the provider services in the local health economy.
and/or
• Activity identified by the provider and recorded as such within national systems (such as SUS+) as for the attention of the CCG.
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
- GDPPR COVID 19 Data
Pseudonymisation is completed within the DSCRO and is then disseminated as follows:
1. Pseudonymised GDPPR COVID 19 data is securely transferred from the DSCRO to the Data Controller / Processor
2. Aggregation of required data will be completed by the Controller (or the Processor as instructed by the Controller).
3. Patient level data may not be shared by the Controller (or any of its processors).
DSfC - NHS East Riding of Yorkshire CCG - STP - Comm — DARS-NIC-349688-V6V0Q
Type of data: information not disclosed for TRE projects
Opt outs honoured: No - data flow is not identifiable, Anonymised - ICO Code Compliant (Does not include the flow of confidential data)
Legal basis: Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 s261(2)(b)(ii)
Purposes: No (Commissioning Support Unit (CSU), Clinical Commissioning Group (CCG), Sub ICB Location)
Sensitive: Sensitive
When:DSA runs 2020-03-20 — 2023-03-19 2020.03 — 2021.05.
Access method: Frequent Adhoc Flow, One-Off
Data-controller type: NHS EAST RIDING OF YORKSHIRE CCG, NHS HULL CCG, NHS NORTH LINCOLNSHIRE CCG, NHS EAST RIDING OF YORKSHIRE CCG, NHS HULL CCG, NHS NORTH EAST LINCOLNSHIRE CCG, NHS NORTH LINCOLNSHIRE CCG, NHS HUMBER AND NORTH YORKSHIRE ICB - 02Y, NHS HUMBER AND NORTH YORKSHIRE ICB - 03F, NHS HUMBER AND NORTH YORKSHIRE ICB - 03K, NHS HUMBER AND NORTH YORKSHIRE ICB - 02Y, NHS HUMBER AND NORTH YORKSHIRE ICB - 03F, NHS HUMBER AND NORTH YORKSHIRE ICB - 03H, NHS HUMBER AND NORTH YORKSHIRE ICB - 03K
Sublicensing allowed: No
Datasets:
- Acute-Local Provider Flows
- Ambulance-Local Provider Flows
- Children and Young People Health
- Civil Registration - Births
- Civil Registration - Deaths
- Community Services Data Set
- 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
- National Cancer Waiting Times Monitoring DataSet (CWT)
- National Diabetes Audit
- Other Not Elsewhere Classified (NEC)-Local Provider Flows
- Patient Reported Outcome Measures
- Population Data-Local Provider Flows
- Primary Care Services-Local Provider Flows
- Public Health and Screening Services-Local Provider Flows
- SUS for Commissioners
- e-Referral Service for Commissioning
- Personal Demographic Service
- Summary Hospital-level Mortality Indicator
- National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
- Improving Access to Psychological Therapies Data Set_v1.5
- Adult Social Care
- Medicines dispensed in Primary Care (NHSBSA data)
- 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:
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)
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.
In addition, North of England Commissioning Support Unit also receive pseudonymised GP data and Social Care data. This is pseudonymised either at source or within North of England Commissioning Support Unit acting as a data processor on behalf of each data controller. This pseudonymisation process is different to that within the DSCRO.
Also, each data source will use a variation of this process so there is no linkage between these data until a common pseudonym has been applied via the DSCRO.
Processing for commissioning will be conducted by North of England Commissioning Support Unit, Optum Health Solutions UK Limited and Kier Business Services Limited and Dr Foster Limited (Hosting the eMBED Health Consortium).
The eMBED Health Consortium is made up of 4 partners:
Kier Group - Kier Business Services Limited
• Dr Foster Limited
• BDO
• Engine
Only two of the organisations process and store data (host the eMBED Health Consortium). BDO and Engine do not process, store or have access to any data.
eMBED are not a legal entity, although they do have an IG Toolkit. Kier and Dr Foster Limited are the relevant legal entities hosting the eMBED Health Consortium.
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. CCGs' outcome indicators.
b. Financial and Non-financial validation of activity.
c. Successful delivery of integrated care within the CCGs.
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 CCGs' 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 CCGs' 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 CCGs' 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 NHS North Lincolnshire CCG, NHS East Riding of Yorkshire or NHS Hull CCGs' regions (including historical activity where the patient was previously registered or resident in another commissioner).
and/or
• Patients treated by a provider where NHS North Lincolnshire CCG, NHS East Riding of Yorkshire or NHS Hull 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 North Lincolnshire CCG, NHS East Riding of Yorkshire and NHS Hull CCG - this is only for commissioning and relates to both national and local flows.
N3i Limited supply IT infrastructure for North of England Commissioning Support Unit and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.
Calderdale and Huddersfield NHS Foundation Trust, Telecity, Telstra and 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.
Microsoft UK supply provide Cloud Services for Liaison Financial Services Ltd and are therefore listed as a data processor. They supply support to the system, but do not access data. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.
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:
Data Processor 1 – NHS 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) and Patient Reported Outcome Measures (PROMs) only is securely transferred from the DSCRO to North of England Commissioning Support Unit.
2. North of England Commissioning Support Unit also receive pseudonymised GP Data and Social Care data. (See i – viii for detail)
3. North of England Commissioning Support Unit add derived fields and link data. Data is stored on a server held within North of England Commissioning Support Unit.
4. Access to the North of England Commissioning Support Unit server (data listed in point 1 and 2 only) is granted to Kier Business Services Limited (Hosting the eMBED Health Consortium) via Role Based Access Control analyse the data and then to Dr Foster Limited (Hosting the eMBED Health Consortium). Kier Business Services Limited and Dr Foster Limited (Hosting the eMBED Health Consortium) provide analysis as point 5 and between them produce different reports, utilising different techniques, to produce the outputs listed at point 5.
5. North of England Commissioning Support Unit and Kier Business Services Limited and Dr. Foster Limited (Hosting the eMBED Health Consortium) 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. North of England Commissioning Support Unit also apply a risk stratification algorithm to pseudonymised SUS+, Local Provider flow and GP data only. Outputs are made available to North of England Commissioning Support Unit analysts and Kier Business Services Limited and Dr Foster Limited (Hosting the eMBED Health Consortium).
7. Aggregation of required data for CCG management use will be completed by North of England Commissioning Support Unit and/or Kier Business Services Limited and Dr Foster Limited (Hosting the eMBED Health Consortium) as instructed by the CCGs.
8. Patient level data will not be shared outside of the Data Processor/Controller and will only be shared within the Data Processors 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.
9. Kier Business Services Limited and Dr Foster Limited (Hosting the eMBED Health Consortium) and the CCGs are permitted to download data in points 1 and 2 to their servers and outputs from point 6.
10. The CCG securely transfer Pseudonymised data back to the provider to:
a) confirm how patients are reported in SUS, and how the commissioner can reliably group these patients into categories for points of delivery;
b) allow for granular data validation whereby a commissioner may query the SUS record, and need to pass it back to the provider for checking; and
c) to allow the provider to undertake further analysis of a cohort of their patients as requested and specified by the
commissioner.
The data transferred to the provider is only that which relates directly to the data previously uploaded by that particular provider.
Kier Business Services Limited and Dr Foster (Hosting the eMBED Health Consortium) will not have access to the
pseudonymisation tool or encryption key used for the data, therefore is unable to re-identify the data effectively rendering the data anonymous.
All access to the North of England Commissioning Support Unit server is managed via Role Based Access Controls.
Commissioning - Data Processor - Optum Health Solutions (UK) Ltd
1. Pseudonymised SUS, Local Provider Data, Social Care Data, Mental Health Services Dataset, Community Services Dataset and GP Primary Care data is securely transferred from North of England Commissioning Support Unit to Optum Health Solutions (UK) Ltd. The data is decoupled from the other national datasets and sent as individual data flows
2. Optum Health Solutions (UK) Ltd provide analysis to:
Whole population segmentation to assess population health needs
Prospective risk scoring for individuals to indicate the likelihood of future adverse events
Predictive modelling to determine individuals at risk and an understanding of the drivers of risk
Longitudinal analysis of intersegmental drift
Identifying individuals who move between complexity classifications and the drivers of these transitions
The production of individual-level theographs to identify gaps in care
3. Allowed linkage is between the datasets contained within point (1) above. GP and Social Care datasets are needed for the processing carried out by Optum to enhance the population health analytics beyond SUS and LPF's which contain only secondary care activity
4. Optum Health Solutions (UK) Ltd then pass the processed, pseudonymised and linked data to the CCG.
5. Aggregates of required data for CCG management use will be completed by Optum Health Solutions (UK) Ltd 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.
7. Optum Health Solutions (UK) Ltd will only be in receipt of data and only be permitted to act as Data Processors for the period specified in the contract with the CCGs.
The data transferred to the provider is only that which relates directly to the data previously uploaded by that particular provider.
North of England Commissioning Support Unit have individual data processing agreements in place with GPs, Local Authorities and the CCGs, to pseudonymise data. Acting on their behalf, North of England Commissioning Support Unit pseudonymises the data as follows:
i. Identifiable GP and Social Care data is submitted to North of England Commissioning Support Unit.
ii. The data lands in a ring-fenced area.
iii. North of England Commissioning Support Unit has access to a pseudonymisation tool. North of England Commissioning Support Unit requests an organisation specific pseudonymisation key from the DSCRO. The key can only be used once. The key is specific to the individual request and the organisation it is being requested for.
iv. The data is then pseudonymised using the organisation specific pseudonymisation tool and DSCRO issued key. The identifiable data is then deleted from the ring-fenced area.
v. To enable linkage to data listed in point 1, North of England Commissioning Support Unit make a request to the DSCRO.
vi. The DSCRO then send a mapping table to North of England Commissioning Support Unit.
vii. A black box uses the mapping table to overwrite the organisation specific pseudonym with the DSCRO pseudonym to enable linkage to NHS Digital released products (under this agreement).
viii. The mapping table if then deleted.
ix. In addition, for social care data only: Social Care organisations have access to the pseudonymisation tool and can request an organisation specific pseudonymisation key from the DSCRO. The key can only be used once and is specific to that date. The organisation then submits the pseudonymised social care data to North of England Commissioning Support Unit. The data then follows from point v.