NHS Digital Data Release Register - reformatted
NHS Somerset Icb - 11x projects
112 data files in total were disseminated unsafely (information about files used safely is missing for TRE/"system access" projects).
DSfC - NHS Somerset CCG IV, RS, Comm & Van — DARS-NIC-43362-G7T9X
Type of data: information not disclosed for TRE projects
Opt outs honoured: No - data flow is not identifiable, Yes - patient objections upheld, Anonymised - ICO Code Compliant, Identifiable (Section 251, Section 251 NHS Act 2006, Mixture of confidential data flow(s) with support under section 251 NHS Act 2006 and non-confidential data flow(s))
Legal basis: Health and Social Care Act 2012 – s261(1) and s261(2)(b)(ii), National Health Service Act 2006 - s251 - 'Control of patient information'. , Health and Social Care Act 2012 s261(1) and s261(2)(b)(ii), Health and Social Care Act 2012 s261(7); National Health Service Act 2006 - s251 - 'Control of patient information'., Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 s261(7), Health and Social Care Act 2012 s261(2)(b)(ii)
Purposes: No (Clinical Commissioning Group (CCG), Sub ICB Location)
Sensitive: Sensitive
When:DSA runs 2019-09-23 — 2022-09-22 2018.06 — 2021.05.
Access method: Frequent adhoc flow, Frequent Adhoc Flow, One-Off
Data-controller type: NHS SOMERSET CCG, NHS SOMERSET ICB - 11X
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
- Community Services Data Set
- National Cancer Waiting Times Monitoring DataSet (CWT)
- SUS for Commissioners
- Civil Registration - Births
- Civil Registration - Deaths
- National Diabetes Audit
- Patient Reported Outcome Measures
- National Cancer Waiting Times Monitoring DataSet (NCWTMDS)
- Adult Social Care
- e-Referral Service for Commissioning
- Medicines dispensed in Primary Care (NHSBSA data)
- Personal Demographic Service
- Summary Hospital-level Mortality Indicator
- 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 South, Central and West Commissioning Support Unit.
The CCG are advised by South, Central and West Commissioning Support Unit whether payment for invoices can be made or not.
Risk Stratification
Risk stratification is a tool for identifying and predicting which patients are at high risk or are likely to be at high risk and prioritising the management of their care in order to prevent worse outcomes.
To conduct risk stratification Secondary User Services (SUS) data, identifiable at the level of NHS number is linked with Primary Care data (from GPs) and an algorithm is applied to produce risk scores. Risk Stratification provides a forecast of future demand by identifying high risk patients. Commissioners can then prepare plans for patients who may require high levels of care. Risk Stratification also enables General Practitioners (GPs) to better target intervention in Primary Care.
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 South, Central and West Commissioning Support Unit.
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
• Ensuring we do what we should
§ Data Quality and Validation – allowing data quality checks on the submitted data
§ Thoroughly investigating the needs of the population, to ensure the right services are available for individuals when and where they need them
§ Understanding cohorts of residents who are at risk of becoming users of some of the more expensive services, to better understand and manage those needs
§ Monitoring population health and care interactions to understand where people may slip through the net, or where the provision of care may be being duplicated
§ Modelling activity across all data sets to understand how services interact with each other, and to understand how changes in one service may affect flows through another
§ Service redesign
§ Health Needs Assessment – identification of underlying disease prevalence within the local population
§ Patient stratification and predictive modelling - to identify specific patients at risk of requiring hospital admission and other avoidable factors such as risk of falls, computed using algorithms executed against linked de-identified data, and identification of future service delivery models
The pseudonymised data is required to ensure that analysis of health care provision can be completed to support the needs of the health profile of the population within the CCG area based on the full analysis of multiple pseudonymised datasets.
Processing for commissioning will be conducted by South, Central and West Commissioning Support Unit.
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.
Vanguard – Commissioning
1. Reviewing current service provision
a. Cost-benefit analysis and service impact assessments to underpin service transformation across health economy
b. Service planning and re-design (development of NMoC and integrated care pathways, new partnerships, working with new providers etc.)
c. Impact analysis for different models or productivity measures, efficiency and experience
d. Service and pathway review
e. Service utilisation review
2. Ensuring compliance with evidence and guidance
a. Testing approaches with evidence and compliance with guidance.
3. Monitoring outcomes
a. Analysis of variation in outcomes across population group
4. Understanding how services impact across the health economy
a. Service evaluation
b. Programme reviews
c. Analysis of productivity, outcomes, experience, plan, targets and actuals
d. Assessing value for money and efficiency gains
e. Understanding impact of services on health inequalities
5. Understanding how services impact on the health of the population and patient cohorts
a. Measuring and assessing improvement in service provision, patient experience & outcomes and the cost to achieve this
b. Propensity matching and scoring
c. Triple aim analysis
6. Understanding future drivers for change across health economy
a. Forecasting health and care needs for population and population cohorts across STPs
b. Identifying changes in disease trends and prevalence
c. Efficiencies that can be gained from procuring services across wider footprints, from new innovations
d. Predictive modelling
7. Delivering services that meet changing needs of population
a. Analysis to support policy development
b. Ethical and equality impact assessments
c. Implementation of NMOC
d. What do next years contracts need to include?
e. Workforce planning
8. Maximising services and outcomes within financial envelopes across health economy
a. What-if analysis
b. Cost-benefit analysis
c. Health economics analysis
d. Scenario planning and modelling
e. Investment and disinvestment in services analysis
f. Opportunity analysis
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
Vanguard – Commissioning
1. Profiling population health and wider determinants to identify and target those most in need
a. Understanding population profile and demographics
b. Identify patient cohorts with specific needs or who may benefit from interventions
c. Identifying disease prevalence. health and care needs for population cohorts
d. Contributing to Joint Strategic Needs Assessment (JSNA)
e. Geographical mapping and analysis
2. Identifying and managing preventable and existing conditions
a. Identifying types of individuals and population cohorts at risk of non-elective re-admission
b. Risk stratification to identify populations suitable for case management
c. Risk profiling and predictive modelling
d. Risk stratification for planning services for population cohorts
e. Identification of disease incidence and diagnosis stratification
3. Reducing health inequalities
a. Identifying cohorts of patients who have worse health outcomes typically deprived, ethnic groups, homeless, travellers etc. to enable services to proactively target their needs
b. Socio-demographic analysis
4. Managing demand
a. Waiting times analysis
b. Service demand and supply modelling
c. Understanding cross-border and overseas visitor
d. Winter planning
e. Emergency preparedness, business continuity, recovery and contingency planning
5. Care co-ordination and planning
a. Planning packages of care
b. Service planning
c. Planning care co-ordination
6. Monitoring individual patient health, service utilisation, pathway compliance experience & outcomes across the heath and care system
a. Patient pathway analysis across health and care
b. Outcomes & experience analysis
c. Analysis to support anti-terror initiatives
d. Analysis to identify vulnerable patients with potential safeguarding issues
e. Understanding equity of care and unwarranted variation
f. Modelling patient flow
g. Tracking patient pathways
h. Monitoring to support NMoC, ACOs, STPs
i. Identifying duplications in care
j. Identifying gaps in care, missed diagnoses and triple fail events
k. Analysing individual and aggregated timelines
7. Undertaking budget planning, management and reporting
a. Tracking financial performance against plans
b. Budget reporting
c. Tariff development
d. Developing and monitoring capitated budgets
e. Developing and monitoring individual-level budgets
f. Future budget planning and forecasting
g. Paying for care of overseas visitors and cross-border flow
8. Monitoring the value for money
a. Service-level costing & comparisons
b. Identification of cost pressures
c. Cost benefit analysis
d. Equity of spend across services and population cohorts
e. Finance impact assessment
9. Comparing population groups, peers, national and international best practice
a. Identification of variation in productivity, cost, outcomes, quality, experience, compared with peers, national and international & best practice
b. Benchmarking against other parts of the country
c. Identifying unwarranted variations
10. Comparing expected levels
a. Standardised comparisons for prevalence, activity, cost, quality, experience, outcomes for given populations
11. Comparing local targets & plan
a. Monitoring of local variation in productivity, cost, outcomes, quality and experience
b. Local performance dashboards by service provider, commissioner, geography, NMOC, STPs
12. Monitoring activity and cost compliance against contract and agreed plans
a. Contract monitoring
b. Contract reconciliation and challenge
c. Invoice validation
13. Monitoring provider quality, demand, experience and outcomes against contract and agreed plans
a. Performance dashboards
b. CQUIN reporting
c. Clinical audit
d. Patient experience surveys
e. Demand, supply, outcome & experience analysis
f. Monitoring cross-border flows and overseas visitor activity
14. Improving provider data quality
a. Coding audit
b. Data quality validation and review
c. Checking validity of patient identity and commissioner assignment
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.
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)
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
Segregation
Where the Data Processor and/or the Data Controller hold both identifiable and pseudonymised data, the data will be held separately so data cannot be linked.
All access to data is audited
Data for the purpose of Invoice Validation is kept within the CEfF, and only used by staff properly trained and authorised for the activity. Only CEfF staff are able to access data in the CEfF and only CEfF staff operate the invoice validation process within the CEfF. Data flows directly in to the CEfF from XXXX and from the providers – it does not flow through any other processors.
Invoice Validation
1. Identifiable SUS Data is obtained from the SUS Repository to the Data Services for Commissioners Regional Office (DSCRO).
2. The DSCRO pushes a one-way data flow of SUS data into the Controlled Environment for Finance (CEfF) in the South, Central and West Commissioning Support Unit.
3. The CSU carry out the following processing activities within the CEfF for invoice validation purposes:
a. Checking the individual is registered to a particular Clinical Commissioning Group (CCG) and associated with an invoice from the SUS data flow to validate the corresponding record in the backing data flow
b. Once the backing information is received, this will be checked against national NHS and local commissioning policies as well as being checked against system access and reports provided by NHS Digital to confirm the payments are:
i. In line with Payment by Results tariffs
ii. are in relation to a patient registered with a CCG GP or resident within the CCG area.
iii. The health care provided should be paid by the CCG in line with CCG guidance.
4. The CCG are notified that the invoice has been validated and can be paid. Any discrepancies or non-validated invoices are investigated and resolved between South, Central and West Commissioning Support Unit 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
Identifiable SUS data is obtained from the SUS Repository to the Data Services for Commissioners Regional Office (DSCRO).
1. 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 South, Central and West Commissioning Support Unit, who hold the SUS data within the secure Data Centre on N3.
2. Identifiable GP Data is securely sent from the GP system to South, Central and West Commissioning Support Unit.
3. SUS data is linked to GP data in the risk stratification tool by the data processor.
4. 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.
5. Once South, Central and West Commissioning Support Unit has completed the processing, the CCG can access the online system via a secure connection to access the data pseudonymised at patient level.
Commissioning
The Data Services for Commissioners Regional Office (DSCRO) obtains the following data sets:
1. SUS
2. Local Provider Flows (received directly from providers)
o Acute
o Ambulance
o Community
o Demand for Service
o Diagnostic Service
o Emergency Care
o Experience, Quality and Outcomes
o Mental Health
o Other Not Elsewhere Classified
o Population Data
o Primary Care Services
o Public Health Screening
3. Mental Health Minimum Data Set (MHMDS)
4. Mental Health Learning Disability Data Set (MHLDDS)
5. Mental Health Services Data Set (MHSDS)
6. Maternity Services Data Set (MSDS)
7. Improving Access to Psychological Therapy (IAPT)
8. Child and Young People Health Service (CYPHS)
9. Diagnostic Imaging Data Set (DIDS)
Data quality management and pseudonymisation is completed within the DSCRO and is then disseminated as follows:
Commissioning – Data Processor - South, Central and West Commissioning Support Unit
1) Pseudonymised SUS, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young People’s Health data (CYPHS) and Diagnostic Imaging data (DIDS) only is securely transferred from the DSCRO to South, Central and West Commissioning Support Unit.
2) South, Central and West Commissioning Support Unit add derived fields, link data and provide analysis to:
o See patient journeys for pathways or service design, re-design and de-commissioning (CSU or CCG).
o Check recorded activity against contracts or invoices and facilitate discussions with providers (CSU or CCG).
o Undertake population health management
o Undertake data quality and validation checks
o Thoroughly investigate the needs of the population
o Understand cohorts of residents who are at risk
o Conduct Health Needs Assessments
3) Allowed linkage is between the data sets contained within point 1.
4) South, Central and West Commissioning Support Unit then pass the processed, pseudonymised and linked data to the CCG.
5) Aggregation of required data for CCG management use will be completed by South, Central and West Commissioning Support Unit or the CCG as instructed by the CCG.
6) Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared.
Vanguard – Data Processor - South, Central and West Commissioning Support Unit
1) Pseudonymised SUS, Local Provider data, Mental Health data (MHSDS, MHMDS, MHLDDS), Maternity data (MSDS), Improving Access to Psychological Therapies data (IAPT), Child and Young People’s Health data (CYPHS) and Diagnostic Imaging data (DIDS) only is held until points 2 – 8 are completed.
2) South, Central and West Commissioning Support Unit receives GP data. GPdData is received as follows:
a. Identifiable GP data is submitted to South, Central and West Commissioning Support Unit
b. The data lands in a ring fenced area for GP data only.
c. There is a Data Processing Agreement in place between the GP and South, Central and West Commissioning Support Unit. A specific named individual within South, Central and West Commissioning Support Unit acts on behalf on the GP. This person has been issued with a black box.
d. The individual requests a pseudonymisation key from the DSCRO to the black box. The key can only be used once. The key is specific to that GP and to that specific date.
e. Before South, Central and West Commissioning Support Unit will receive the data from the ring fenced area, they require confirmation that the identifiable data has been deleted. clear data will only be processed by substantive employees of the data controller and processors
f. South, Central and West Commissioning Support Unit are then sent the pseudonymised GP data with the pseudo algorithm specific to them.
3) South, Central and West Commissioning Support Unit also receive a pseudonymised flow of social care data. Social Care data is received as follows:
a. The social care organisation is issued with their own black box solution.
b. The social care organisation requests a pseudonymisation key from the DSCRO to the black box. The key can only be used once and is specific to that date.
c. The social care organisation submits the pseudonymised social care data to the CSU with the pseudo algorithm specific to them
4) Once the pseudonymised GP data and social care data is received, South, Central and West Commissioning Support Unit make a request to the DSCRO.
5) The DSCRO check the dates of the key generation (Point 2d and 3b).
6) The DSCRO then send a mapping table to South, Central and West Commissioning Support Unit
7) South, Central and West Commissioning Support Unit then overwrite the organisation specific keys with the DSCRO key.
8) The mapping table is then deleted.
9) The DSCRO then pass the pseudonymised SUS, local provider data, Mental Health (MHSDS, MHMDS, MHLDDS), Maternity (MSDS), Improving Access to Psychological Therapies (IAPT), Child and Young People’s Health (CYPHS) and Diagnostic Imaging (DIDS) securely to South, Central and West Commissioning Support Unit for the addition of derived fields, linkage of data sets and analysis
10) Social care data is then linked to the data sets listed within point 9.
11) A flow of SUS data is sent separately to South, Central and West Commissioning Support Unit where it is linked with pseudonymised GP Data. Algorithms are applied to the pseudonymised linked data and then it is linked to the data sets listed within points 9 and 10.
12) South, Central and West Commissioning Support Unit then pass the processed, pseudonymised and linked data to the University of York for economic evaluation.
13) Aggregation of required data for CCG management use will be completed by South, Central and West Commissioning Support Unit or the University of York as instructed by the CCG.
14) Patient level data will not be shared outside of the CCG and will only be shared within the CCG on a need to know basis, as per the purposes stipulated within the Data Sharing Agreement. External aggregated reports only with small number suppression can be shared.
GDPPR COVID-19 CCG - Pseudo — DARS-NIC-407929-Q6Z6L
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 2020-10-01 — 2021-03-31 2021.01 — 2021.05.
Access method: One-Off, Frequent Adhoc Flow
Data-controller type: NHS SOMERSET CCG, NHS SOMERSET ICB - 11X
Sublicensing allowed: No
Datasets:
- GPES Data for Pandemic Planning and Research (COVID-19)
- COVID-19 Ethnic Category Data Set
- COVID-19 Vaccination Status
- 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).