NHS Digital Data Release Register - reformatted

Prescqipp Cic projects

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

PrescQIPP CIC Medicines dispensed in primary care pseudo anonymised data DARS application — DARS-NIC-408951-K3C1Y

Type of data: information not disclosed for TRE projects

Opt outs honoured: Anonymised - ICO Code Compliant, No (Does not include the flow of confidential data)

Legal basis: Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 – s261(2)(b)(ii), Health and Social Care Act 2012 – s261(2)(a)

Purposes: Yes (Consultancy)

Sensitive: Non-Sensitive

When:DSA runs 2021-11-17 — 2022-11-16 2022.01 — 2024.11.

Access method: Ongoing

Data-controller type: PRESCQIPP CIC

Sublicensing allowed: No

Datasets:

  1. Medicines dispensed in Primary Care (NHSBSA data)

Objectives:

PrescQIPP CIC (Data Controller) is a Community Interest Company and is self funding this particular work through the company's main core income stream which is subscription fees paid by NHS Commissioners. The majority of the company's funding comes from the service subscribers - the Clinical Commissioning Groups (CCGs), Commissioning Support Units (CSUs) and Health Boards that pay an annual fee to access the full range of the service resources. Through a democratic process, the service subscribers tell PrescQIPP CIC which resources they would like them to produce during the year. Subscription income is ring-fenced for all work that is specifically for the company's subscribers of which this data request application supports. PrescQIPP CIC's strategy and financial decision making is also overseen by their Council of Members, which is made up of senior-level subscribers from across the PrescQIPP community. Sometimes, PrescQIPP CIC are also commissioned by other NHS organisations to deliver specific pieces of work. For example, they have previously been commissioned by the Eastern Academic Health Science Network and the NHS England East Anglia Area Team to deliver prescribing related projects. The funding for this type of project work is ring-fenced for specific outcomes as agreed with those organisations and is not part of this application.

PrescQIPP CIC already processes prescribing data for England and Wales. The team produce a range of scorecards and dashboards with indicators to support NHS commissioners and prescribers to monitor prescribing and changes over time. The current data they process (not part of this application) under their core services is not identifiable and in the case of England data, it is available in the public domain. Medicines optimisation looks at the value which medicines deliver, making sure they are clinically-effective and cost-effective. It is about ensuring people get the right choice of medicines, at the right time, and are engaged in the process by their clinical team. Processing this data on behalf of the NHS subscribers is a service they have offered to support medicines optimisation and the bulletins that they produce. Benchmarking data and being able to identify variation in prescribing is something that has been done with the prescribing data across the NHS for many years and is a key tool to improve medicines optimisation and helps drive change. Having access to the pseudonymised patient level data requested under this agreement, it is hoped, will allow the team to develop further indicators to support clinical review in patients and improve medicines optimisation and medicines safety. These indicators will be aligned to their clinical resources and it is hoped, will help support implementation of medicines optimisation across the country.

Having access to this data may also allow the team to review and report on prescribing and medicines safety changes and issues that have arisen because of the COVID (Coronavirus Disease) pandemic.

The team plan to report on changes in prescribing and identify areas which may need further review. The team have already done this using the population level data and would like to further refine the resources on the patient level data which will be aggregated with small numbers supressed in line with the HES analysis guide. It is hoped that this will enable healthcare professionals and commissioners to identify any medicines safety priorities and action changes as appropriate. For example, anticoagulation prescribing post COVID review to ensure switches were done safely and warfarin discontinued in patients switched to a DOAC (Direct Oral Anticoagulant). PrescQIPP CIC has requested data going back to April 2018 to allow them to monitor the impact of COVID. It is hoped that they will be able to monitor prescribing pre, during and post COVID to deliver meaningful and clinically relevant data for commissioners and healthcare professionals.

Although the National Health Service Business Services Authority( NHSBSA) do have certain indicators on ePACT2 (electronic Prescribing, Analysis and Cost data system where the prescribing data is held and can be accessed by the NHS), the team do not plan to replicate these indicators, but have a new set of indicators looking at patients on high risk or high volume polypharmacy to support NHS staff in identifying areas that need review and subsequently patients that need to be reviewed. The indicators will be high level, giving prescribers an indication of the numbers of patients that need to be reviewed. Medicines optimisation and reviewing over prescribing is a high priority for the NHS and therefore, data to support these projects is needed. The data cannot be minimised to high risk patients only as the team need to be able to include all medicines and patients in their service to NHS subscribers.

Justification for processing the data:
Under GDPR regulations, Article 6 (1) (f) processing of this data is necessary for the organisation's legitimate interests and the legitimate interests of a third party and under GDPR regulation Article 9 (2) (h) processing is necessary for health and social care purposes on the basis of Union or Member State law. The relevant basis in UK law is set out in the Data Protection Act (DPA) 2018, in Schedule 1, condition 2, clause f - the management of healthcare systems or services. As the controller of the data PrescQIPP CIC will be processing the data to provide services to the NHS commissioners who in turn will work with practices to review their prescribing at a local level. PrescQIPP CIC as the controller will not receive any patient identifiable information throughout the process and only work with the pseudonymised data.

The team currently provide a range of scorecards and dashboards with indicators to support NHS commissioners and prescribers to monitor prescribing and changes over time. This data is available to Clinical Commissioning Groups, Primary Care Networks and General Practices across England and for the medicines policy team at NHS England. It is hoped that having access to the pseudonymised data will allow the team to provide more information to these NHS organisations who can then use the data to support improving medicines optimisation and patient care.

The team are requesting pseudonymised medicines dispensed in primary care data to support medicines optimisation for all of England. This data is not available through any other source, and the team would not be able to build the indicators NHS organisations would need to support improvement in practice without this data.

The team are requesting access to all the medicines dispensed in primary care data at a pseudonymised level because the team plan to produce indicators to support medicines optimisation in general practice. The team would like the full data set which has not been aggregated and would like unsuppressed data. The plan is to update the scorecards monthly and monitor trends over time to allow commissioners to monitor progress against any changes implemented. PrescQIPP CIC do intend to renew this agreement once it has expired.

As PrescQIPP covers England, Wales, NI and Scotland, the team are requesting all the data for England, as CCGs will need to be able to look at their own data indicators once the team have done the scorecards. The team are only requesting the medicines dispensed in primary care pseudonymised data set. The team have not requested any high risk or patient identifiable data and have not applied for any other data set.

PrescQIPP are working with current CCG subscribers to ensure that budgets are carried forward into Integrated Care Systems (ICSs)/ Integrated Care Boards (ICBs) for 2022 to ensure the service can continue. PrescQIPP's services will be provided to ICS/ICB going forwards.

The data controller is PrescQIPP CIC, who will also process the data. As the data controller, PrescQIPP CIC will determine the purposes for which and the way any personal data will be processed, the team are however only requesting pseudonymised prescribing data. Commissioners, Primary Care Networks and GP practices will be using the indicators that the team produce to monitor prescribing. The resulting indicators will be aggregated with small numbers supressed In line with the HES analysis guide. The team will give them the opportunity to request specific indicators that they feel would be useful to support improved medicines optimisation and medicines safety.

Expected Benefits:

The benefits to the subscribers who are NHS organisations is that they receive a set of indicators relating to medicines optimisation priorities, to help them monitor and implement change in primary care, to improve patient outcomes around medicines optimisation.

It is hoped that the indicators relating to the change in prescribing and medicines safety issues as a result of COVID will enable healthcare professionals and commissioners to identify where change is needed and ensure that the specific safety measures are actioned at a patient level.

Individual healthcare professionals may use the benchmarking data to identify where their unit are outliers on specific indicators compared to their peers and where they can improve on medicines optimisation and medicines safety. Within the individual practice, healthcare professional would then need to use a search on their own practice clinical systems to identify these patients and action any reviews or changes in medication needed.

PrescQIPP publish a specific set of indicators for these organisations monthly and review the indicators on an annual basis. Indicators are based on what is currently a priority for review and target dates for implementing change are decided by commissioners locally or by NHS England. The indicators all measure medicines optimisation or medicines safety and allow practices to review their prescribing. It is hoped that having access to the pseudonymised medicines dispensed in primary care data would enrich the indicators the team produces and allow practices to reflect on their prescribing and implement change in individual patients which would be identified at practice level by the prescriber. Trend charts may allow prescribers and NHS commissioners and policy makers to monitor change in practice and monitor the improvements made.

The data is used only to support the processes and the team do not set target dates for achievement.

The potential benefits that may be realised are reduced prescribing costs where medicines need to be stopped or switched to a cost effective alternative or reduced admissions related to medicines harm or reduced complications related to medicines safety issues. It is difficult to quantify the magnitude of impact as the team will not be implementing the changes to prescribing.

The timescales will be, once the data is received from NHS Digital, the team would expect some initial indicators to be available to Clinical Commissioning Groups, Primary Care Networks and General Practices by the end of the next calendar month. This would allow the team time to collate and process the data.

Outputs:

The team will be producing dashboards and scorecards with specific indicators to help commissioners and prescribers improve medicines optimisation in primary care and monitor prescribing at a local level.

One of the key outputs will be related to prescribing and medicines safety issues that have arisen due to the COVID pandemic. PrescQIPP CIC will produce indicators on changes in prescribing that have resulted from COVID allowing commissioners and healthcare professionals to identify and review any issues.

Some of the images in the dashboards may be used in presentations by the team to show CCGs and Health Boards the data and discuss the indicators. The dashboard charts may also be used by commissioners at a local level and added to reports, presentations, and meeting papers to discuss prescribing and medicines optimisation at a local level. All the data in the dashboards will be aggregate data with small numbers supressed and processed into indicators. The full NHS Digital data set will not be available through the dashboards.

The dashboards and scorecards will be used by commissioners and prescribers as part of their normal day to day activities, as policy makers or clinicians wishing to improve medicines optimisation and medicines safety.

The data will be aggregated and published on PrescQIPP's website in a visualisation tool which would not be identifiable from the raw data. The visualisations are published for subscriber access only through a password protected website. The subscribers are NHS commissioners in primary care. The data would not be accessible to the public.

Data may be linked with QoF data and depravation data to provide a denominator comparison across commissioners, PCNs and Practices. This will only be to provide denominators for certain indicators and will not lead to the pseudonymised data becoming identifiable.

The team would update the dashboards monthly.

The medicines data is not deemed disclosive and information on a GP level is available in the public domain. However, should the published information pose a risk of re-identification, the following suppression methodology should be applied:

· Zeros should be shown.
- 1-7 to be rounded to 5.
· Any other numbers rounded to nearest 5.
· Rounding unnecessary for averages etc.
· Percentages calculated from rounded values.
· If zeros need to be suppressed, round to 5.

Processing:

1. Dataflows: NHS Digital Medicines Dispensed in Primary Care dataset. This dataset is pseudonymised and will be securely transferred via Secure Electronic File Transfer (SEFT) by NHS Digital to PrescQIPP on a monthly basis. The data will then be downloaded as a file to an encrypted external hard drive only.

2. Query, aggregate, join, and download: The raw monthly pseudonymised data file will be accessed via an encrypted hard drive via statistical software to aggregate and create the data sources needed. These resulting outputs (aggregated, small numbers suppressed in line with the HES Analysis guidelines) will be saved to a secure OneDrive folder. The raw monthly data will not be saved to a One Drive folder.

3. Datasets, reports, and dashboards: The new aggregated datasets extracted under this agreement will be added to PrescQIPP's existing services (dashboards/scorecards) to support further medicines optimisation for NHS subscribers. The aggregated dataset will not be linked to any datasets already held by PrescQIPP.

The team are not requesting identifiable data and have taken measures to ensure the security of the data. Once downloaded, the data will be processed by PrescQIPP's data team and published as indicators on a dashboard for medicines optimisation teams to review their prescribing.

The team will not be providing any data to NHS Digital.

The team will only publish on the subscriber access only (password protected) website once it has been processed into our scorecard. The data the team publish will be aggregated with small numbers supressed and not identifiable at a patient level. It will never be published on a public facing page as the data is useful for the NHS subscribers to be able to analyse the data and produce outcomes that will be beneficial to the patients/public but the data alone would not be useful to the public directly. The aggregated data being included only in PrescQIPP's dashboards and scorecards is the specialist service that is provided to service subscribers. The data will never be identifiable as the downloaded data set the team receive from NHS Digital under this agreement.

PrescQIPP CIC will be processing the data at each stage.

Data may be linked with QoF (Quality and outcomes Framework) data and deprivation data to provide a denominator comparison across Commissioners, Primary Care Networks (PCNs) and Practice (official measure of relative deprivation for small areas (lower-layer super output areas) in England). This will only be to provide denominators for certain indicators and will not lead to the pseudonymised data becoming identifiable. For example, the team might do patients prescribed 3 or more diabetes medicines per 1000 QoF registered diabetes patients in the practice. The data linkage will be at overall practice/ commissioner level and not linked at patient level.

PrescQIPP CIC confirm that data processing is only carried out by substantive employees of PrescQIPP CIC who have been appropriately trained in data protection and confidentiality.

The team will download the data directly from NHS Digital via a Secure Electronic File Transfer (SEFT) account. The data will then be downloaded onto an encrypted external hard drive and aggregate/ minimise and pull the data the team need from it as a new data source. The external hard drive will be at an employee’s address as the team work virtually but the equipment is all owned by PrescQIPP.

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).