Client Health Data - GIRFT extension program at the Royal National Orthopaedic Hospital (RNOH) NHS Trust

The Royal National Orthopaedic Hospital NHS Trust (RNOH) requires access to NHS England data for the purpose of the following programme of work:

The Getting it Right First Time (GIRFT) extension Programme.

GIRFT is a well-established and well regarded improvement programme that was conceived by Royal National Orthopaedic Hospital (RNOH) and transferred to NHS England in 2021. Upon transfer of the GIRFT programme to NHS England it was agreed that RNOH would continue to develop and deliver additional GIRFT related services through a ‘GIRFT extension programme’ in close collaboration with NHS England. This would enable RNOH to continue to provide ad hoc GIRFT review services for NHS providers in England and other providers (including independent sector) that are outside the scope of NHS England’s statutory responsibilities.

The following is a summary of the aims of the GIRFT extension programme provided by the Royal National Orthopaedic Hospital (RNOH):

To ensure consistency of the NHS England of GIRFT metric outputs, it is vital that all GIRFT metrics are calculated in the same way from the same source dataset used for the NHS England GIRFT programme.

This requires NHS England to share its GIRFT dataset and provide RNOH with access to the GIRFT coding recipes in the NHS England UDAL (Unified Data Access Layer) secure data environment, and to enable receipt and processing of RNOH client data within UDAL for processing so that outputs can be compared accurately against GIRFT metrics for NHS providers. This will include processing private patient data for independent sector providers that also provide significant NHS services.

Requests to use the GIRFT extension programme will follow the same process as the main GIRFT programme. Specifically:

- GIRFT works with leading clinicians to develop relevant clinical metrics, using nationally available data to identify unwarranted variation in clinical services’ outputs and outcomes. These highly detailed benchmarks are then used to underpin clinical discussions with trusts across more than 40 specialties, supporting NHS providers to improve clinical quality, efficiency, and effectiveness in the delivery of clinical services.

- RNOH will receive requests from interested UK NHS or independent sector clients wishing to undertake a GIRFT review of their services for the purpose of understanding and improving services. These requests will be discussed with NHS England GIRFT team to ensure that they are in line with the Direction of the NHS England GIRFT programme.

- If agreed to go forward, RNOH will contract with clients to set out a clear basis for sharing and processing data for a GIRFT review.

The following NHS England Data will be accessed:

·       Hospital Episode Statistics (HES) Admitted Patient Care and HES Outpatients

·       Emergency Care Data Set (ECDS)

·       Diagnostic Imaging Dataset (DID)

These datasets are necessary to track the patient journey and pathways through the health and care system and any associated outcomes.

The level of the Data will be:

- Pseudonymised

The Data will be minimised as follows:

- Limited to data between 2021 to latest available (for the duration of the DSA)

- Data for the whole of England is required.

The lawful basis for processing personal data under the UK GDPR is:

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

The lawful basis for processing special category data under the UK GDPR is:

Article 9(2)(j) - processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

The funding is provided by the RNOH.

Edge Health is a processor of RNOH and is responsible (under the instruction of RNOH) for conducting the analysis in the UDAL secure data environment.

NHS England considers that the commercial interests associated with this collaboration are well balanced compared with the public benefits.

Although technically speaking RNOH’s GIRFT services are provided as commercial services, the trust does not regard it as a commercial venture and is more about continuing to promote the GIRFT methodology of data driven service improvement to a wider range of health services, ultimately benefiting patients and the NHS. Any profit that is made from delivering this service is effectively returned to the NHS, since RNOH is a leading NHS provider. For independent sector organisations, the motivation to have a GIRFT review is mainly to effect service improvement as most GIRFT metrics focus on quality of outcomes. Whilst there will undoubtedly be commercial benefits from following GIRFT improvement recommendations such benefits are realised by improving service quality, experience and outcomes for patients.

NHS England will grant access to RNOH via the Unified Data Access Layer (UDAL) – a secure data management system within NHS England that enables patient data to be processed and made available for analytical purposes.

UDAL accommodates a series of tools, which enable users to explore patient or aggregate data, to create standardised reports and dashboards, and create statistical models.

NHS England, acting as a processor for RNOH, allows RNOH client data to be uploaded to UDAL so that GIRFT metrics can be applied accurately and consistently

NHS England, acting as processor for RNOH, calculates GIRFT metrics from client data so they can be presented against the England NHS providers for benchmarking.

All processing is carried out by Edge Health Ltd in the UDAL secure environment and RNOH covers all costs associated with the work.

For each RNOH client, Edge Health Ltd undertakes two sets of analysis in parallel:

- Preparation of relevant GIRFT benchmarking metrics for England NHS providers using NHS England GIRFT datasets. This includes any England NHS data associated with RNOH clients where this is submitted to national datasets (e.g. NHS services provided by independent sector clients).

- Preparation of any RNOH client data required for benchmarking comparison, using NHS England GIRFT metric coding recipes. All metrics are presented as aggregate data.

The NHS England and RNOH client datasets are not linked in any way but once analysis is complete, aggregate data results are presented together for benchmarking comparison.

Some metric values for the RNOH client being reviewed may not have small numbers suppressed (where this is necessary to understand the service) but are only shared with the client. However, comparative benchmarking data for England NHS providers are always presented with small numbers suppressed.

The aggregate outputs as described above are shared with the RNOH client, and are the only data that leaves the NHS England UDAL environment.

NHS England does not access the RNOH client data for any purpose other than in its capacity as processor for RNOH.

The Data will not be transferred to any other location.

The Data will be stored on servers at NHS England (UDAL).

The Data will be accessed by authorised personnel via remote access.

The Controller(s) must confirm and provide evidence upon audit by NHS England that access via any remote device complies with the data security obligations within this DSA and the Data Sharing Framework Contract.

For remote access:

- Remote access will only be from secure locations situated within the territory of use (as further restricted elsewhere within the DSA if so done) stated within this DSA;

- Access controls granting users the minimum level of access required are in place;

- Remote access is only via secure connections (e.g., VPNs or secure protocols) to protect data;

- Multifactor authentication (MFA) is required for remote access;

- Device security, including up-to-date software and operating systems, antivirus software, and enabled firewalls are utilised for the remote access;

- All remote access is undertaken within the scope of the organisation’s DSPT (or other security arrangements as per this DSA) and complies with the organisation’s remote access policy.

The above applies in addition to any condition set out elsewhere within the DSA (e.g. who may carry out processing, and for what purpose).

The Data will not leave England at any time.

Access is restricted to employees of RNOH or Edge Health.

All personnel accessing the Data have been appropriately trained in data protection and confidentiality.

NHS England, acting as processor for RNOH, calculates GIRFT metrics from client data so they can be presented against the England NHS providers for benchmarking.

The outputs are Data Packs, which include reports containing descriptive statistics, graphs and an explanation of the outputs.

NHS England has considered the public benefit associated with this work based on relevant criteria set out in the National Data Guardian Guidance and believes there is a sufficient case to justify sharing data as proposed. Key points in relation to this are summarised below:

1. Firstly, the GIRFT work carried out by RNOH provides independent sector or devolved clients with a clear, benchmarked mechanism for checking the quality of care, identifying good practice to learn from and areas of poorer practice which need to be addressed. This represents a direct benefit to the public.

2. Independent sector providers deliver services for a significant proportion of the England population and therefore improvements in the quality of NHS or private healthcare services provided for this group of patients will benefit the public directly.

3. In addition to the direct benefits to patients identified above, there are indirect benefits to the NHS since better outcomes from these providers can reduce the burden on the NHS e.g. reducing emergency admissions or subsequent elective admissions following

complications after surgery; reducing the need for follow up and support services etc.

4. Similar benefits can be seen where the RNOH GIRFT work assists the NHS in devolved nations to improve, as there is considerable overlap in the populations served near borders (e.g. England and Wales) and hospitals in the devolved nations also deliver

services for many patients that live in England (e.g. when on holiday) with follow up care provided once back at home in England.

5. However perhaps the key area for NHS England is the indirect benefit of capturing learning for the NHS. It is agreed with RNOH that the learning from all GIRFT Extension Programme projects must be shared with NHS England. Principally this is concerned

with identification or improvement of treatments or intervention, or health and care system design, to improve health and care outcomes or experience. The work carried out by RNOH provides NHS England with a significant opportunity to access

intelligence and examples of good practice from services that are not normally under its remit and to share this with the wider NHS.

Yielded Benefits is not a requirement for new applications.