Information Governance
 considerations in developing
   Healthcare Applications
              Andrew Glover
Head of Information (Governance & Services)

         Leeds Teaching Hospitals
Data Protection Act (1998)
• Personal Data relating to living individuals
   – Accurate
   – Secure
   – Not excessive (only collect data that is
     required)
   – Not kept longer than necessary
   – Should not be transferred/held outside the EEA
 Deceased Patients are covered by the Common Law
                 of Confidentiality
Caldicott Guidelines
• Justify the purpose(s)
• Don't use patient identifiable information unless it
  is absolutely necessary
• Use the minimum necessary patient-identifiable
  information
• Access to patient identifiable information should
  be on a strict need-to-know basis
• Everyone with access to patient identifiable
  information should be aware of their
  responsibilities
• Understand and comply with the law
Developing Applications
• Accurate
  – Data Entry Accuracy (Master File driven, linked field
    selection)
  – Missing / Invalid Data Reports
  – Consider feeding demographic data from primary
    patient system


• Secure
  – Username & Password or Smartcard (consider role based
    access)
  – Transaction Log (Access, Add & Update)
  – Session Timeout
  – De-Identification
  – Patient identifiable information should cache to secure
    devices / servers
Developing Applications
• Not Excessive
  – Only collect the data that is required for the purpose of
    the application


• Not kept longer than required
  – Retention Schedule of the Records Management: NHS
    Code of Practice
  – Consider building retention date into application


• Should not be transferred outside the EEA
  – Cloud computing (where is data held)
Other considerations
• Subject Access Request / ATHR
• Ensure Application can interface with other
  Healthcare systems
• From 2015 NHS Number is mandated for primary
  patient identifier
• Equality & Diversity Information
• Be adaptable to changes in legislation
   – Changes to European Directive
   – Caldicott review
Reference
                Data Protection Act (1998)
    http://www.legislation.gov.uk/ukpga/1998/29/contents

                   Caldicott Guidelines
http://www.connectingforhealth.nhs.uk/systemsandservices/info
gov/caldicott
      Records Management: NHS Code of Practice
http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/P
                         ublications
               PolicyAndGuidance/DH_4131747
                    Connecting for Health
                 http://www.connectingforhealth.nhs.uk/

Information governance considerations in developing healthcare applications

  • 1.
    Information Governance considerationsin developing Healthcare Applications Andrew Glover Head of Information (Governance & Services) Leeds Teaching Hospitals
  • 2.
    Data Protection Act(1998) • Personal Data relating to living individuals – Accurate – Secure – Not excessive (only collect data that is required) – Not kept longer than necessary – Should not be transferred/held outside the EEA Deceased Patients are covered by the Common Law of Confidentiality
  • 3.
    Caldicott Guidelines • Justifythe purpose(s) • Don't use patient identifiable information unless it is absolutely necessary • Use the minimum necessary patient-identifiable information • Access to patient identifiable information should be on a strict need-to-know basis • Everyone with access to patient identifiable information should be aware of their responsibilities • Understand and comply with the law
  • 4.
    Developing Applications • Accurate – Data Entry Accuracy (Master File driven, linked field selection) – Missing / Invalid Data Reports – Consider feeding demographic data from primary patient system • Secure – Username & Password or Smartcard (consider role based access) – Transaction Log (Access, Add & Update) – Session Timeout – De-Identification – Patient identifiable information should cache to secure devices / servers
  • 5.
    Developing Applications • NotExcessive – Only collect the data that is required for the purpose of the application • Not kept longer than required – Retention Schedule of the Records Management: NHS Code of Practice – Consider building retention date into application • Should not be transferred outside the EEA – Cloud computing (where is data held)
  • 6.
    Other considerations • SubjectAccess Request / ATHR • Ensure Application can interface with other Healthcare systems • From 2015 NHS Number is mandated for primary patient identifier • Equality & Diversity Information • Be adaptable to changes in legislation – Changes to European Directive – Caldicott review
  • 7.
    Reference Data Protection Act (1998) http://www.legislation.gov.uk/ukpga/1998/29/contents Caldicott Guidelines http://www.connectingforhealth.nhs.uk/systemsandservices/info gov/caldicott Records Management: NHS Code of Practice http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/P ublications PolicyAndGuidance/DH_4131747 Connecting for Health http://www.connectingforhealth.nhs.uk/