Access to Civil Registration Deaths – Local Authority Collaborative Suicide Prevention Strategy

Collaborative Suicide Prevention Strategy

Suicide presents a significant risk to public health within Sussex. The UK Government sets out the need for developing and improving the support provided by local public services in helping to reduce the number of suicides nationally. The World Health Organisation highlights suicide as a major public health risk, accounting for one in 100 of all deaths globally, estimating that for every suicide there are 20 non-fatal suicide attempts. Every death by suicide is an individual tragedy and a cause of huge distress to friends, families, and communities. For every one suicide, it is estimated that there can be up to 135 people significantly impacted. For any one year, approximately 24,000 people in Sussex were affected by suicide. Within Sussex, the number of people who have enduring and in many cases a life-long negative impact from suicide is substantial.

The Local Authority Teams at East Sussex County Council (ESCC), Brighton & Hove City Council (BHCC) and West Sussex County Council (WSCC) are working collaboratively on a suicide prevention strategy. The councils would like to receive relevant PCMD data relating to deaths by suicide for all three local authorities to support further analyses required by the programme. This would be an on-going piece of work to understand and monitor the situation in Sussex, identify trends and further insights that will inform work to reduce the risk of suicide in the population. This analysis will look at places of death, methods of suicide, age, sex, area of residence (including persons living outside of Sussex who die by suicide within Sussex) and other socio-demographic factors such as area deprivation and employment/socio-economic groupings. The deaths data is of significant value to the Local Authorities in enabling analysts to respond to local public health needs. Evaluations of deaths in their local area allows local authorities to perform the following:

a) Measuring the health mortality or care needs of the population of Sussex,

b) Planning, evaluating or monitoring suicide prevention care policies, services or interventions; and,

c) Protecting or improving the public health, the risk factors pertaining to sections of the population, investigating specific areas of local concern relating to the health of the local population, or the effectiveness of medical treatments.

The deaths data contains identifiable data which is required when linking into other datasets to enhance and verify the statistics produced, or to investigate specific areas of local concern relating to the health of the local population, as in the production of suicide audits by linking into hospital / GP / social care data. Such local investigations will reflect local need and thus vary in relation to the specific local authority, but the detail below provides specific examples of such local investigations which provide evidence on why identifiable data is needed in order to carry out the purposes stated within a), b) and c) above.

The data controllers will only be permitted to process the data in the way outlined in this application.

In relation to mortality data :

Suicide Audit – As part of on-going (or the introduction of) suicide audit processes identifiable information will be required to support this work. Such audits require specific identifiable fields, including postcode of usual residence and postcode of place of death (further refined using the place of death text) to analyse and investigate of deaths in public places to support work on suicide prevention strategies and the identification of hotspots and locational characteristics for suicide. For example, exact postcode is used to calculate distance from home address to identify suicide hotspots which are a distance from place of resident as a further means of classifying risk. NHS number, date of death and date of registration fields are used when conducting local audits at the coroner’s office, to match their records with the death record in order to supplement information which is subsequently aggregated within the final internal report.

To expand on what is noted above, postcode of residence and place of death (further refined using the place of death text) is used for hotspot mapping and in particular is used to inform suicide prevention work through target hotspot areas of location types within the county and undertake specific preventative work. Pseudonymised data would be insufficient as lower super output areas or partial postcode) cover too large an area to identify exact locations and features or calculate distance from home, especially in more dispersed rural areas, where locations may be many miles apart. This granularity of data is required since the local authorities are where appropriate taking specific locally based action rather than just authority wide activity. The suicide audit process involves collecting information from services such as police, healthcare providers and GP practices of the factors involved in the suicide and NHS number, date of death and other identifiable data will be essential for doing this. As with the hotspot work this is about understanding risk, detecting local issues to inform evidence-based interventions addressing known local factors.

Postcode of usual residence and postcode of place of death (further refined using the place of death text) are used for the analysis and investigation of deaths in public places to support work the identification of hotspots and locational characteristics for suicide– with identification of types of areas (e.g. parks, railway lines, pavements) as well as particular locations. This level of analysis enables preventative work to be targeted to high risk areas (both in terms of residence as well as occurrence). As a specific example relating to one Local Authority, it carried out work that identified a number of suicides at a particular railway location, and hence facilitated suicide prevention training with staff members at their local Railway Station.

Legal Basis for Processing Data:

Article 6(1)(e) - (processing is necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller)

Local Authorities

Local Authorities have a legal responsibility under Section (1)(2)(3)(4)(5)(6)(7) of the Care Act 2014 to conduct tasks that are in the public interest to:

(1) Promoting individual well-being

(2) Preventing needs for care and support

(3) Promoting integration of care and support with health services etc.

(4) Providing information and advice

(5) Promoting diversity and quality in provision of services

(6) Co-operating generally

(7) Co-operating in specific cases

(8) Duty to meet needs for care and support

The task(s) are necessary (but are by no means an exhaustive list), but provides an indication of the many tasks required under Part 1 of the Care Act 2014 as the council has an obligation to the public to deliver services that are a necessity to the local population - from whom funding is provided to deliver these services/tasks in the form of Council Tax.

Local Authorities have a duty under Section 74 (1)(2)(3)(4) of the NHS Act 2006 to supply goods and services:

(1) In the Local Authorities (Goods and Services) Act 1970 (c. 39) the expression “public body” includes—

(a) any Strategic Health Authority, Special Health Authority or Primary Care Trust, and

(b) so far as relates to his functions under this Act, the Secretary of State.

(2) Subsection (1) has effect as if made by an order under section 1(5) of the Local Authorities (Goods and Services) Act 1970 and may be varied or revoked by such an order.

(3) Each local authority must make services available to each NHS body acting in its area, so far as is reasonably necessary and practicable to enable the NHS body to discharge its functions under this Act.

(4) “Services” means the services of persons employed by the local authority for the purposes of its functions under the Local Authority Social Services Act 1970 (c. 42).

Article 9(2)(h)

(processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the 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 services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3)

Article 9(3)

(Personal data referred to in paragraph 1 may be processed for the purposes referred to in point (h) of paragraph 2 when those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.)

Data Protection Act 2018

Section 11 - Special categories of personal data etc: supplementary

(1)For the purposes of Article 9(2)(h) of the GDPR (processing for health or social care purposes etc), the circumstances in which the processing of personal data is carried out subject to the conditions and safeguards referred to in Article 9(3) of the GDPR (obligation of secrecy) include circumstances in which it is carried out—

(a)by or under the responsibility of a health professional or a social work professional, or

(b)by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law.

Legal basis for Processing Confidential Data:

The Health Service (Control of Patient Information) Regulations 2002 - Regulation 3:

(1) confidential patient information may be processed with a view to:

(a) diagnosing communicable diseases and other risks to public health;

(b) recognising trends in such diseases and risks;

(c) controlling and preventing the spread of such diseases and risks;

The Local Authorities have a Caldicott Guardian/Clinical Director. The Caldicott Guardian/Clinical Director is a health professional and acts as a guardian responsible for safeguarding the confidentiality of patient information in-line with the specific requirement of Regulation 7(2) of COPI

Patient and Public Engagement

The Sussex Suicide Prevention Strategy has been developed with support from place-based suicide prevention groups and representatives for the Community and Voluntary sector. Representatives from these groups have been approached for their view and support of the pan-Sussex strategy. The Strategy and Action plan received positive support.

In 2022, prior to the publication of the latest national strategy, an engagement exercise took place with key stakeholders from the Sussex Suicide Prevention partnership, giving partners the opportunity to shape the ‘Statements of Intent’ for national Action Areas. The approach of this strategy is based on the action areas of the 2023 national strategy.

The Strategy plans to expand on engagement with local organisations, the strategy will look to engage National Suicide Prevention Alliance (NSPA), aiming to support local organisations and develop a Sussex lived experience local network.

UPDATE TO DEATH DATA PROVISIONING

Due to the planned decommissioning of the Primary Care Mortality Dataset (PCMD) by NHS England during the period of this Data Sharing Agreement, the provision of the PCMD data will be replaced by Civil Registrations of Death Dataset. The data processed will remain the same and after a full refresh of all the historic data has been provided in the new format, the Local Authorities will be required to destroy the previously supplied PCMD Data.

No Data will be flowing from NHS England to the Data Controllers under this agreement. The Data processed for the purposes outlined in this agreement will be data held by the Data Controllers, which has been disseminated under the Data Sharing Agreements listed below:

DARS-NIC-50105-C8P5V - East Sussex County Council

DARS-NIC-37123-L4W1M - West Sussex County Council

DARS-NIC-44378-T7F0X - Brighton and Hove City Council

This agreement will only remain active while the Data Sharing Agreements listed above are in place.

A minimum dataset will be agreed between the three local authorities for the purposes of the Suicide Prevention Strategy to minimise the data being transferred. Once agreed, the Local Authorities will transfer the data to an environment hosted by ESCC. The data would be transferred from via gov.uk email within an encrypted and password protected data file. The Local Authorities will appoint analysts to process the data hosted by ESCC within the Public Health Intelligence Team. Users may process the data to produce statistical output for purpose outlined in this agreement, this may be for internal review or summarised as anonymous data for publication.

Data will be stored on a confidential file server only to be accessed by appointed employees of the Data Controllers. Analysis would be undertaken within this secure area and any outputs shared would adhere to the data disclosure rules clearly set out by this data sharing agreement for the handling of this mortality data i.e., data suppression on small numbers etc. Various extracts from the deaths data will be taken for relevant time periods and localities to enhance and inform the collaborative work.

The data will only be processed by the aforementioned Local Authority employees in fulfilment of this suicide audit public health function, and will not be transferred, shared, or otherwise made available to any third party, including any organisations processing data on behalf of the Local Authorities or in connection with their legal function. Such organisations may include Commissioning Support Units, Data Services for Commissioners Regional Offices, any organisation for the purposes of health research, or any Business Intelligence company providing analysis and intelligence services (whether under formal contract or not). Data cannot be shared with any third party who is not identified in this Agreement at anything other than an aggregated level (with small numbers suppressed) and where stated within this agreement.

Conditions of supply and controls on use

The Director of Public Health within each Local Authority will be the Information Asset Owners for the deaths data and be responsible on behalf their employing Local Authority to NHS England for ensuring that the data supplied is only used in fulfilment of the approved public health purposes as set out in this agreement. The Local Authorities confirm that the Director of Public Health is a contracted employee to the permanent role within the Local Authority, accountable to the Chief Executive.

Data must be processed according to the terms in this Agreement. Data must only be used for public health statistical purposes and not used for administrative and other activities such as list cleaning. This data may only be linked to other data with explicit permission from NHS England, and only as described in this Agreement.

Typical outputs expected of the suicide prevention strategy are expected to contribute to the following:

a) Joint Strategic Needs Assessments (JSNAs);

b) Joint Health and Wellbeing Strategies;

c) the annual report of the Director of Public Health;

d) reports commissioned by the Health and Wellbeing Board;

e) public health and wellbeing strategies and plans;

f) public health advice to NHS commissioners;

i) Suicide audits (this specifically requires NHS number)

l) responses to internal and external requests for information and intelligence on the health and wellbeing of the population.

The specific content and target dates for these outputs will be for the Local Authority to determine, although it is required to comply with national guidance published by the Department of Health, Public Health England and others as appropriate, for example on the timetable for publishing refreshed JSNAs.

All outputs will be of aggregated data (with small numbers suppressed).

The suicide prevention strategy is implemented in order to improve public health and will result in local adjustments to services to reduce mortality where possible and inform decisions and policies.

Benefits of using deaths data:

As well as this strategic focus, the data informs specific actions, decisions and changes within the area covered by the Local Authority. Within suicide prevention work, the data has aided the identification of suicide hotspots and risk factors which has informed the local suicide prevention strategy which has directed interventions and changes within the county. As the data informs the Joint Strategic Needs Assessment, Health and Wellbeing Board and other multi-agency work, and has a direct relationship with commissioning plans and specific actions, the benefits are achieved collective across the local health and care economy through the Health and Wellbeing Board membership organisations (including health commissioners, social care, public health, council members, police and probation services, Healthwatch and other community representatives) and beyond. The benefit to the local population is that health, social care and public health services are tailored to the issues and areas of greatest needs and are focused on reducing health inequalities, with specific reference to life expectancy and mortality rates. Reductions in premature mortality rates are influenced by the design and targeting of local services to address the differences highlighted through an analysis of the data. Specific interventions around suicide and accident prevention use information from the data to identify specific hotspots and risk factors locally, which in turn are used to protect the public health. The Collaborative Suicide Prevention Strategy is hoped to maximise the effectiveness of these benefits for individuals across all three Local Authority geographies.

The Collaborative Suicide Prevention Strategy seeks to implement improvements in the following areas aimed at reducing instances of suicide within the area:

- Improving data and evidence to ensure that effective, evidence-informed and timely interventions can be developed and adapted.

- Support the Local Authorities ability to deliver tailored, targeted support to priority groups, including those at higher risk of suicide. Addressing common risk factors linked to suicide at a population level to provide early intervention and tailored support.

- Identification and reductio of access to means and methods of suicide where this is appropriate and necessary as an intervention to prevent suicides.

- Improving the provision of effective bereavement support to those affected by suicide.

Specific steps taken to protect the health of the local population using deaths data within a Local Authority will include the setting of priorities within the Annual Public Health Report, the Joint Health and Wellbeing Strategy and the commissioning plans of local health and care organisations. These strategic documents are underpinned by an analysis of mortality data including local, regional and national variations for the purposes of identifying priority areas, highlighting where health inequalities are greatest, identifying the conditions contributing to the greatest levels of premature and preventable deaths, and identifying areas for further investigation. The health of the local population is also protected through the monitoring of monthly trends in mortality rates to identifying any emerging trends or sudden increases. The data is also vital to facilitate the local investigation of mortality rates for individual GP practices (consistent with the recommendations of the Shipman Inquiry) and to investigate differences between geographic areas as required. Mortality data is also used to inform the location of services and social marketing activities to address the areas of greatest need within the county.

Statistical outputs using mortality data include local breakdowns of mortality rates by area, deprivation, age sex and ICB locality (preventable deaths, circulatory disease, cancer and suicide) for Health and Wellbeing Board and Public Health outcomes reports; setting and life expectancy for JSNA community profiles; detailed analyses of overall and condition-specific mortality rates, life expectancy; population projections for non-standard geographic areas (including new town and development areas); and the analysis of mortality rates from specific conditions for service areas and health needs assessments as required.

Not stated in the register.