Transcript Document

The Information
Strategy and DPA
Dawn Monaghan
Group Manager
Information Commissioners Office
The Information Strategy
ICO Views
• Welcome general aims
• Keen to ensure that the ‘human’ elements are
considered as well the technical
• Encouraged re Data being an ‘individuals’ data
• Integrated (shared) data a good thing
• Positive about the drive to a culture of
transparency
Key Initiatives and ICO involvement
• Information Governance Review Panel
• Code of Practice on confidentially
• Confidential Advisory Group
• National Information Advisory Group
• Regular Stakeholder meetings and contact with
other interested parties
Specific Work
• HSCA 2012 and its interfaces with the DPA
• New data flows and clarification of Data
Controllers’ in the new structures
• Internal Policies within the ICO
• Care.data - GPES
• On Line Access to Records
HSCA 2012 interfaces with the DPA
• HSCA 2012 s254 NHSE may ‘direct’ HSCIC to
‘establish and operate a system for the collection
….’
• HSCA 2012 s255 Any person may ‘request’ that
the IC to ‘establish and operate a system ….’
• HSCA 2012 s258 Before establishing a system the
‘IC must consult’
•
HSCA 2012 s259 The Information Centre may
‘require and request provision of information’
New data flows/clarification of
Data Controllers
• Care Providers
• Collection of data sets by HSCIC
• HSCIC to CCG’s, LAPH, NHSE
• CSU’s /Area Teams/DMIC’s/ LAPH
• Data Controller relationships?
Internal Policies within the ICO
• Notification
• DPA Complaints/ FOIA s50 cases
• Enforcement investigations
• Tribunal cases
• Enquiries
Care.data - GPES
• NHSE/HSCIC/Care Providers
• Data Controller responsibilities
• s259 the ‘power to require’
• Engagement of s35 of DPA
• s27 (3) (4) DPA ‘..to the extent to which they are
inconsistent with the disclosure in question…’
On Line Access to Records
• Pilot schemes - to date considered and compliant
• Welcome the Roadmap from RCGP’s
• Like more involvement as it goes forward
• May improve accuracy
On Line Access to Records
• Opinions and 3rd party data
• Subject Access Requests
• Enforced Subject Access
• Technical and organisational measures
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