DSfC - CIPHA - CV19

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Objective for processing

[11 paragraphs unchanged] The Data Controller involved in this agreement also have an existing agreement for commissioning purposes (NIC-140059).

Processing activities

PROCESSING CONDITIONS: [109 paragraphs unchanged]

Benefits reported

[1 paragraph unchanged] 1) Enhanced case finding tool for COVID-19 [1 paragraph unchanged] 2) Elective recovery tool (PTL Tool) [1 paragraph unchanged]

Unchanged: Expected output, Expected measurable benefits.

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Data controllers: − CHESHIRE EAST COUNCIL; − CHESHIRE WEST AND CHESTER COUNCIL; − HALTON BOROUGH COUNCIL; − KNOWSLEY METROPOLITAN BOROUGH COUNCIL; − LIVERPOOL CITY COUNCIL; − SEFTON METROPOLITAN BOROUGH COUNCIL; − ST HELENS COUNCIL; − WARRINGTON BOROUGH COUNCIL; − WIRRAL BOROUGH COUNCIL

Objective for processing

The overarching purpose for this agreement is to support a set of [19 words unchanged] targeting of direct care to vulnerable populations across the Cheshire & Merseyside Sustainable Transformation Partnership (C&MSTP). Integrated Care Board (C&M ICB). [1 paragraph unchanged] Although CMSTP C&M ICB is made up of over 450 organisations (including more than 350 GP practices) for the purposes of this Data Sharing Agreements Agreement it has been determined that the 8 Clinical Commissioning Groups and 8 Local Authorities ICB are the Joint Data Controllers. These organisations form sole data controllers. The data under this Agreement will be processed under GDPR Article 6(1)(e) - Necessary for the membership performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, and Article 9(2)(h) - Necessary for the purposes of preventive or occupational medicine, for the assessment of the Data Access working capacity of the employee, medical diagnosis, the provision of health or social care, or treatment or the management of health or social care systems and Asset Group within the STP and so for the purpose of this agreement are deemed to be Joint Data Controllers. service. The COVID related population health analytics will be achieved via analysis of [32 words unchanged] person level pseudonymised data available to the local placed based intelligence teams that being within the CCG and Local Authorities. ICB. This will enable them to support the local system including the COVID [19 words unchanged] as local with COVID planning, which includes support to General Practice and PCN’s PCNs in intelligence required. [2 paragraphs unchanged] Dashboard 1: COVID sit rep reporting: this suite of reports will show the daily situation of COVID in Cheshire and Mersey Merseyside to aid the monitoring and management of outbreaks and incidents including cases, mortality, hospital admissions, testing and outbreaks. It’s Its audience is system wide including local Recovery Cells and Hospital and Out of Hospital cells, all designated by government to locally manage the pandemic. It will enable them C&M ICB to have the same up to date information on the spread and challenges in the pandemic and the post pandemic period so they can make informed population management decisions. Dashboard 2 Capacity and Demand: This dashboard will assist in monitoring and [42 words unchanged] there is enough capacity to meet that demand and allow the Cells and STO described above to take informed actions to control and prevent the spread [15 words unchanged] system capacity including Cheshire and Merseyside region, sub regional teams i.e. North Mersey, individual CCG’s Mersey and Primary Care Networks. Dashboard 3 Epidemiology: This dashboard will enable monitoring and recognition of trends [65 words unchanged] responsible for planning and those responsible for planning a COVID response with PCN’s. PCNs. [2 paragraphs unchanged] The 9 CCGs Data Controller involved in this agreement also have an existing agreement for commissioning purposes (NIC-140059) (NIC-140059).

Processing activities

[1 paragraph unchanged] 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. England. All access to data is auditable by NHS England. Data Processors must only act upon specific instructions from the Data Controller. The Data Controller must keep a record of locations the data is processed and stored. These addresses must be within the UK. The Data Controller should minimise the number of processing and storage locations to prevent excessive processing. NHS England may request a record of processing and storage locations at any time. Data can only be stored at the addresses listed under storage addresses. [1 paragraph unchanged] Patient level data will not be linked other than as specifically detailed within this Data Sharing Agreement. Data released will only be used for the purposes laid out in the application/agreement. NHS Digital England reminds all organisations party to this agreement of the need to comply [31 words unchanged] 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. The former CCG(s) has submitted their Data Security Protection Toolkit (DSPT) for 23/24. The ICB will submit their DSPT in line with the 22/23 submission timetable. The following CCG(s) previously occupied the footprint of the ICB: NHS HALTON CCG NHS KNOWSLEY CCG NHS SOUTH SEFTON CCG NHS SOUTHPORT AND FORMBY CCG NHS ST HELENS CCG NHS WARRINGTON CCG NHS WIRRAL CCG NHS CHESHIRE CCG NHS LIVERPOOL CCG All data previously disseminated to the CCG has been transferred to the ICB. DATA PROCESSORS Data Processors must be listed in section 5b of this Data Sharing Agreement. These include Cloud and IT infrastructure providers. The Data Controller should ensure appropriate data processing agreements with all data processors contracted to undertaking work referenced within this agreement [1 paragraph unchanged] There is no requirement for the analytical teams to re-identify patients, but in the cases of the development of cohorts of patients considered to be at risk, risk stratification or other similar primary use tools, the data controllers may need the facility to provide identifiable results back [5 words unchanged] 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 Additionally clinicians, made aware of a case by case basis. National data opt outs are not applied in these number of cases as that they are believe would need intervention may request re-identification for the purposes of that direct care which follows the legal basis of implied consent. purpose. An example of a request for the re-id of patients for direct care may be; These instances of re-identification will generally be carried out as programmes of work or, rarely, on an individual/small group 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. The following are typical (generic) examples of instances where the re-identification process may be used: [1 paragraph unchanged] The CCG user can filter data to show for example the number of A&E attendances in a given period for each patient. The CCG user can then flag to the relevant GP of the patient any patients [11 words unchanged] the patient(s) care thus potentially reducing future costs and minimising future risk. Polypharmacy re-IDs Population Stratification 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. Dashboard 4 allows clinicians to identify individuals with certain characteristics that would be vulnerable to the effects of COVID-19 and offer interventions to avoid adverse outcomes. [1 paragraph unchanged] 1. The CCG identifies a patient cohort (typically small numbers) to be re-identified for the purpose of direct care. 1. Data pseudonymised with the open pseudonymiser is sent from DSCRO to Graphnet Health Ltd 2. The CCG sends a re-id request to the DSCRO. This may be done through the CCG or CSU’s Business Intelligence (BI) Tool, or through a manual form. 2. The SALT key used for the pseudonymisation is also sent to Graphnet Health Ltd 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 requestor’s relationship with patients in the data 3. Graphnet uses the SALT key to create a mapping table to link the pseudonym back to the NHS Number 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. 4. The pseudonymised SUS data is then converted back to identifiable data using the mapping table for direct care purposes related to COVID-19 by approved users only. 5. DSCROs retain an audit trail of all re-id requests All direct care use cases which require the re-identification of person identifiable data are designed with the principles of data minimisation and controlled access using role based access controls and row level security; ensuring that only those individuals with a legitimate purpose for accessing data can. 6. National Data opt outs are not applied for the purpose of direct care Where data is included in a direct care analytics tool, the CIPHA pseudonym is used as the main patient identifier. Individuals are able to re-identify patient identifiable data on request by a re-identification button in the report which identifies the patient NHS number and name to the individual. This re-identification button has role based access controls specifically assigned for the re-identification purpose. Each time re-identification is requested, data about the re-identification is recorded for audit purposes. Aggregated reports only with small number suppression can be shared externally as set out within NHS Digital guidance applicable to each data set. Graphnet has an established protocol for the assurance and acceptance of user requests to the population health platform. This process is also augmented by pre-checks and authorisation made by a delegated Trusted Authority, Mid Mersey Data Analytics. The process is such: a. User request is logged with Mid Mersey Data Analytics b. Mid Mersey Data Analytics log a Cloud access request on the Graphnet Cloud Access system. c. The Graphnet Cloud access team validate the user request and set up user access requests. Security to Power BI analytics is secured by assigning an appropriate role based on the RBAC model and assigning row level security based on a requested ODS code. Access can also be assigned for a set period of time to allow for fixed term staff access, assuring that access is removed when a contract ends. The Cloud access desk will communicate with the user the details of their access and the details of the organisations they have been assigned by email. All information is stored on the Jira helpdesk system and is fully auditable allowing users to identify which users currently have access to analytics at any point in time. Aggregated reports only with small number suppression can be shared externally as set out within NHS England guidance applicable to each data set. [3 paragraphs unchanged] All access to data is auditable by NHS Digital England in accordance with the Data Sharing Framework Contract and NHS Digital England terms. [4 paragraphs unchanged] • Patients who are normally registered and/or resident within the CCG ICB regions (including historical activity where the patient was previously registered or resident in another commissioner). [1 paragraph unchanged] • Patients treated by a provider where the CCG ICB are the host/co-ordinating commissioner and/or has the primary responsibility for the provider [8 words unchanged] is only for commissioning and relates to both national and local flows. [1 paragraph unchanged] • Activity identified by the provider and recorded as such within national systems (such as SUS+) as for the attention of the CCG ICB - this is only for commissioning and relates to both national and local flows. [33 paragraphs unchanged] 3. Graphnet Health Ltd also receive data directly from providers (see points i - v iv [Data From Providers below] for details) [1 paragraph unchanged] 5. Graphnet Health Ltd also receive the specific SALT key for this project from the DSCRO. The key is used to create a mapping table from the pseudonym to NHS Number for the purposes for direct care only by approved users. The data is therefore considered identifiable once transferred to Graphnet Health Ltd. [1 paragraph unchanged] 6. Graphnet Health Ltd then pass the processed, pseudonymised and linked data to the Data Controllers. ICB. GPs are also given access to patients to whom they have a legitimate relationship to. 7. Patient level data will not be shared outside of the Data [39 words unchanged] with small number suppression can be shared as set out within NHS Digital England guidance applicable to each data set. [16 paragraphs unchanged] v. The identifiable data is then deleted from the segregated area For clarity, the reidentification of individuals for GP Direct Care purposes is carried out by the DSCRO.

Expected measurable benefits

Benefits at Cheshire and Mersey Region, CCG ICB and Local Authority level The Cheshire and Merseyside Health Care partnership (C&M HCP) is made up [30 words unchanged] reintroducing planned care capacity cross both acute, community and mental health providers. Demand It is hoped that demand and capacity reports will enable the C&M HCP and the nine places [5 words unchanged] etc) to be sighted on system demand and respond with capacity accordingly. [1 paragraph unchanged] Available once data flows. • C&M Covid dashboards including cases rates, testing rates and system metrics such as hospital admissions and local mortality rates will enable local health care systems within the C&M footprint to understand the current Covid situation and respond with appropriate policy. Available within 3-6 months. • An epidemiology dashboard will allow place-based decision makers to identify the population characteristics of people presenting for tests, cases and mortality to better understand the nature of the pandemic and identify if there are particular cohorts that are consuming testing at a greater rate than others to help manage testing capacity. Available within 3-6 months. • A specific testing dashboard will help place-based decision makers to identify geographical Covid hot spots and drill down to identify patterns and/or vulnerable cohorts for management. This may allow more targeted intervention at place-based or more local geographies. Available within 3-6 months. [1 paragraph unchanged] Available within 3-6 months. What are the potential benefits for GP Practices and Primary Care Networks (PCNs)? • The system will provide the data to enable the C&M HCP and place-based NHS organisations to follow the NHSE planning guidance which includes the following: “Restore NHS services inclusively, so that they are used by those in greatest need. This will be guided by new, core performance monitoring of service use and outcomes among those from the most deprived neighbourhoods and from Black and Asian communities, by 31 October 2020. Ensure datasets are complete and timely, to underpin an understanding of and response to inequalities. All NHS organisations should proactively review and ensure the completeness of patient ethnicity data by no later than 31 December 2020, with general practice prioritising those groups at significant risk of COVID-19 from 1 September 2020. Collaborate locally in planning and delivering action to address health inequalities, including incorporating in plans for restoring critical services by 21 September; better listening to communities and strengthening local accountability; deepening partnerships with local authorities and the voluntary and community sector; and maintaining a continual focus on implementation of these actions, resources and impact, including a full report by 31 March 2021.” https://www.england.nhs.uk/publication/implementing-phase-3-of-the-nhs-response-to-the-covid-19-pandemic/ What are the benefits for GP Practices and Primary Care Networks (PCNs)? [1 paragraph unchanged] Available within 3-6 months. • Analysis of the characteristics of people affected by COVID in their populations and identification of local hotspots may allow targeted interventions based on specific risk factors, for example local shielding advice, patient remote monitoring and specific treatment interventions (such as early use of steroids in selected patients in community). This may lead to reduced morbidity and mortality and better patient outcomes. • Analysis of the characteristics of people affected by COVID in their populations and identification of local hotspots may allow targeted interventions based on specific risk factors, for example local shielding advice, patient remote monitoring and specific treatment interventions (such as early use of steroids in selected patients in community). This may lead to reduced morbidity and mortality and so better patient outcomes. What are the potential benefits for patients? Available within 3-6 months. What are the benefits for patients? [1 paragraph unchanged] Available within 3-6 months. [1 paragraph unchanged] Available within 3-6 months. • It is hoped the above will result in improved patient well-being and a reduction in morbidity and mortality associated with Covid infection, over the course of the pandemic. • It is hoped the above will result in improved patient well-being and a reduction in morbidity and mortality associated with Covid infection. Available over the course of the pandemic, may be seen within 3-6 months.

Benefits reported

Not stated in the previous version; added here.

Use of NHS England data outlined within this agreement has contributed to the following:

Enhanced case finding tool for COVID-19

CIPHA have developed an enhanced case-finding tool to enable clinicians across a range of services to access the health record of their patients. This has enabled more informed, insightful conversations with the patient as well as allowing service managers to understand more detail about patients using their services. The tool enhances clinical safety by providing the health history of a patient to support clinical decision-making, ensuring the correct intervention is offered. Use of this tool has allowed clinicians to appropriately manage patients where targeted support can aid in caring for vulnerabilities of at risk individuals.

Elective recovery tool (PTL Tool)

This PTL report in CIPHA is designed to support the elective recovery programme by providing detail on waiting lists and insight into the patients waiting for treatments. CIPHA have linked NHS-Digital waiting list data with existing CIPHA data sources to provide insight into those on the waiting list in terms of demographics, long term conditions, department and other protected characteristics. The PTL tool enables the ICS to understand their waiting list and identify underlying issues that may prevent the backlog from reducing. Use of this tool has allowed the ICS to identify patients who have been on waiting lists within particular time periods, supporting clinician decision-making into how to appropriately manage those patients to help reduce overall waiting times for patients. Specifically this has tool has continued to support the ICS in reducing the number of cancer 62-day pathways (patients with and without a decision to treat, but yet to be treated) waiting 63 days or more after an urgent suspected cancer referral.

Applicant organisation: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Organisation type: renamed from Sub ICB Location to ICB - Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Data controllers: renamed from NHS Cheshire and Merseyside ICB to NHS Cheshire and Merseyside Integrated Care Board. The same organisation under a new name, so not counted as a change.

Changed only in punctuation, spacing or capitalisation: Expected output.

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Data controllers: + WIRRAL BOROUGH COUNCIL · − WIRRAL METROPOLITAN BOROUGH COUNCIL - PUBLIC HEALTH

Processing activities

[9 paragraphs unchanged] Patient level data will not be shared outside of the Data Controllers / Data Processors 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. 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 CSU’s 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 requestor’s 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 [70 paragraphs unchanged]

Unchanged: Objective for processing, Expected output, Expected measurable benefits.

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Objective for processing

[11 paragraphs unchanged] The 9 CCGs involved in this agreement also have a an existing agreement for commissioning purposes (NIC-140059)

Benefits reported

Stated in the previous version and removed here.

Yielded Benefits is not a requirement for new applications.

Unchanged: Processing activities, Expected output, Expected measurable benefits.