Data Flow Mapping NHS South, Central and West CSU · Data Flow Mapping NHS South, Central and West...

Data Flow Mapping NHS South, Central and West CSU

NHS BUCKINGHAMSHIRE CLINICAL COMMISSIONING GROUP

Data Flow Mapping; NHS Data Security and Protection Toolkit 2018-19

Last Updated:

BCCG Contact:

Email:

Why Risk Assessment Risk Treatment

Reference number

if applicable

(This is a free text box)

Team/Directorate Who sends the information


Direction of

flow

(This is a drop-

down menu)

Recipient


What data is sent/received


What is the

category of

data

(This is a drop-

down menu)

What level of

protection is applied

to the data

(This is a drop-down

menu)

Data format

(This is a drop-

down menu)

Additional Information


Where is the data stored

(This is a drop-down menu)

How is the data stored

secure?

(This is a drop-down menu

or free text box)

How is access evidenced?


Number of

records per

transfer

(This is a

drop-down

Frequency of transfer


Purpose of Transfer


Method used for transfer


How is the information protected

in transit?

(This is a drop-down menu or free

text box)

Comment


Where is the data

processed/transferred?


What would the IMPACT be if the data

was no longer available?


What is the LIKELIHOOD of the data

no longer being available?


Risk Score

(automatic scoring)

Please provide the mitigation taken on all data flows that score

a Moderate Risk (yellow) to Extreme Risk (Red)


What conditions for processing are you

relying upon?


What additional conditions for processing are

you relying upon where you are processing

special categories of data?


Common Law Duty of Confidence


What agreements are in place for

this data flow


What is the (b) Contract, (c) Legal Obligation or

(e) legislation relied upon


Data Privacy Impact Assessment (DPIA)

version/date. IF THE FLOW EXISTING BEFORE

MAY 2018 THEN A DPIA NOT MANDATORY

Information/Data Sharing Agreement/Protocol

version/date. THIS IS STILL MANDATORY EVEN

IF AN EXISTING FLOW BEFORE MAY 2018

LT01 Long Term Conditions CCG Member GP practices In-flow CCG Long Term Conditions

individual team members

Personal health details and test

results/diagnoses. (e.g. this may

relate to NHS Diabetes Prevention

Programme (NHS DPP), Primary

Care Development Scheme, Live Well

Stay Well NHS health improvement

service for adults )

Special

Categories of

personal data

None - Identifiable Electronic Staff view details only as shown on screen in primary care practices - nothing brought back to CCG

offices (Lori, Kiera, Abi, Angela less so). Primary Care practice staff retain control and are the only

people who access the EMIS system. The purpose is to assist member practices to assist

troubleshooting in relation to record keeping and reporting in relation to projects/services cited (NHS

Diabetes Prevention Programme (NHS DPP), Primary Care Development Scheme, Live Well Stay

Well NHS health improvement service for adults). Identifiable data does not otherwise form part of the

reporting outputs of these projects and so corresponding DPIAs/DSA's for these projects specify all

flows as anonymous.

Specific software solution Password protected network

drive/system

IT Access/User Reports as part of

user audit trail

Less than 5 When required Ensure quality clinical care for

patients

Within software solution Password protected Within UK 1 3 3 None for us as member GP practices are the data controller (e) Performance of a task in the public

interest or the exercise of official

authority

(h) Medical and Health diagnosis, treatment or

management of health or social care systems

and services

1.Contract in Place.

2. Data Sharing Agreement in Place

a) CCGs - NHS Act 2006.

b) GP Practices - NHS England's powers to

commission health care under NHS Act 2006 or

to delegate such powers to CCGs.

Existing before May 2018? DSA Version Date;

Contract Version Date:

LT02 Long Term Conditions CCG Member GP practices In-flow Diabetes Specialist Nurse and

Transformation Support

Officers

Diabetic care evidence into practice

(Gill Dunn)

Special

Categories of

personal data

None - Identifiable Electronic Specific software solution Password protected network

drive/system


user audit trail

Less than 5 When required Support clinical need and best

practice



authority



and services

(a) Consent (implied, explicit,

informed)

1. Data Sharing Agreements with

GP practices.






LT03 Long Term Conditions CCG member GP practices In-flow CCG Diabetes Specialist Nurse

and Transformation Support

Officers

Diabetic care evidence into practice

(Gill Dunn)

Special

Categories of

personal data

None - Identifiable Electronic Specific software solution Password protected network

drive/system


user audit trail


practice



authority



and services


informed)


GP practices.








Officers

Insulin group initiation work (Gill

Dunn).

Special

Categories of

personal data

None - Identifiable Electronic We are encouraging practice to manage diabetes patients in group sessions - training on blood

sugars. We help practices to do that; working with diabetic specialist nurses and practice nurses to

run these events. Nurse does not actually access EMIS where patient data would be held.


drive/system


user audit trail


practice



authority



and services


informed)


GP practices.








Officers

Locality Multi-Disciplinary Teams - Special

Categories of

personal data

Anonymous Electronic Meetings chaired by Head of Long Term Conditions to discuss complex patients and their families.

Name excluded from EMIS records, however patient names may then be discussed in verbal

discussions. This is a transformational arrangement with CCG in service development role to support

establishment only - in future the Chair and co-ordinators would be employed by a GP practice.

NHSMail Password protected network

drive/system


user audit trail

Less than 5 Monthly Support clinical need and best

practice

NHSmail to NHSmail Password protected Within UK 3 3 9 None for us as member GP practices are the data controller (e) Performance of a task in the public


authority



and services


informed)





UC01 Urgent Care Acute providers:

Buckinghamshire Healthcare

NHS Trust

Milton Keynes University

Hospitals NHS Trust

Oxford University Hospitals

NHS Trust

Luton and Dunstable NHS

Trust

In-flow CCG Urgent Care Team Medically fit for Discharge Lists

Password protected but not

anonymised.

Report is electronic with CCG staff

involved in one or more of the

following supporting measures:

(1) On site daily joint health and social

care medically fit review (before list is

circulated to named users)

(2) Daily system (escalations following

above meeting)

(3) Weekly Friday directors escalation

call (escalations from above and

directors top 20 (see below)

Special

Categories of

personal data

None - Identifiable Electronic Report formats are varied; some include NHS number and DOB and some don't.

(1) On site daily joint health and social care medically fit review (before list is circulated to named

users). Will likely involve discussion of patient named

(2) Daily system (escalations following above meeting) - less likely to involve discussion of patient

names

(3) Weekly Friday directors escalation call (escalations from above and directors top 20 (see below)

Password protected but not anonymised. OUH MK adhoc, routinely from Wexham, medically fit.

Wexham stopped end of March citing GDPR. Since not had list dtoc and EDB have increased.

NHSMail Password protected files IT Access/User Reports as part of

user audit trail

21 to 100 Daily Expedite Discharge/mitigate

against delayed transfers of

care

email within NHS NHSmail [secure] encryption File is password protected Within UK 4 4 16 Daily escalation calls in absence of copies of lists, plus daily

system calls DO WE KNOW THE MEDICAL CONDITION OF

THE PATIENT?

(e) Performance of a task in the public


authority


b) NHS Foundation Trusts: Health & Social Care

(Community Health and Standards) Act 2003.

c) NHS Trusts: National Health Service and

Community Care Act 1990.

DPIA DONE? As per NHS standard commissioning contract in

place.

UC01a Urgent Care Acute provider: Frimley

Health NHS Foundation Trust

In-flow CCG Urgent Care Team Medically fit for Discharge Lists

Password protected but not

anonymised.

Report is electronic with CCG staff

involved in one or more of the

following supporting measures:

(1) On site daily joint health and social

care medically fit review (before list is

circulated to named users)

(2) Daily system (escalations following

above meeting)

(3) Weekly Friday directors escalation

call (escalations from above and

directors top 20 (see below)

Personal data Pseudonymised Electronic Subset of above for Buckinghamshire patients in Frimley only Secure network Restricted Access Folder 21 to 100 Daily Expedite Discharge/mitigate


care

email within NHS NHSmail [secure] encryption File is password protected Within UK 4 4 16 Daily escalation calls in absence of copies of lists, plus daily

system calls DO WE KNOW THE MEDICAL CONDITION OF

THE PATIENT?



authority






DPIA DONE? As per NHS standard commissioning contract in

place.

UC02 Urgent Care SCW Commissioning

Support Unit

In-flow CCG Urgent Care Team CSU data – CSU long stay patient

report (strandeds)

Personal data Pseudonymised Electronic Only PAS number identifies the patient NHSMail None SUS data 21 to 100 Monthly Establish if patients are still

admitted patients - discuss with

partners to facilitate discharge

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 4 16 (e) Performance of a task in the public


authority

Contract in Place a) CCGs - NHS Act 2006.





NHS standard contract.

Data Processing Agreements.

UC03 Urgent Care CCG Urgent Care Team Out-flow Acute providers:


NHS Trust


Hospitals NHS Trust


NHS Trust

Luton and Dunstable NHS Trust

CSU data – CSU long stay patient

report (strandeds)

Personal data Pseudonymised Electronic Urgent Care and Elective - we send a version of the report to providers (with no PID) to cross

reference whether patients are still in the acute trust

NHSMail None SUS data 21 to 100 Monthly Establish if patients are still

admitted patients - discuss with

partners to facilitate discharge -

provider cross reference



authority








NHS Trust


Hospitals NHS Trust


NHS Trust


Trust

In-flow CCG Urgent Care Team and

CHC Commissioning Manager

and Adult Social Care

Directors top 20 weekly password but

not anonymised (stranded)

Personal data None - Identifiable Electronic Forename and surname NHSMail Password protected files 21 to 100 Weekly Expedite Discharge/mitigate


care - top 20 longest stay

patients



authority


informed)

NHS standard contract. a) CCGs - NHS Act 2006.





UC05 Urgent Care CHC Commissioning

Manager

Out-flow Oxford Health Directors top 20 weekly - only those

patients whose delay sits with

Continuing Care team (stranded)

Personal data None - Identifiable Electronic Forename and surname NHSMail Password protected files 21 to 100 Weekly Expedite Discharge/mitigate


care - top 20 longest stay

patients



authority


informed)








NHS Trust


Hospitals NHS Trust


NHS Trust


Trust

In-flow CCG Urgent Care Team and/or

Directors on Call and/or

Locality Business Support

Manager given numbers

related to patients in Aylesbury

localities

Adhoc funding requests via Vicki

Parker from community, or from BHT.

Abi Edwards keeps a copy.

Personal data None - Identifiable Electronic Name, DOB and NHS number NHS shared drive Restricted Access Folder Less than 5 When required (e) Performance of a task in the public


authority


informed)






F01 Finance SCWCSU In-flow Line Managers Expenses claims Personal data None - Identifiable Electronic Cloud storage Password protected network

drive/system

SEL expenses system 21 to 100 Monthly Staff Expenses claim Encrypted secure email

service

Encrypted (approved) Within UK 4 2 8 Manual calculations of expenses if necessary and disaster

recovery plan on CSU systems



authority

SLA in place a) CCGs - NHS Act 2006. N/A N/A

F02 Finance Staff members Out-flow SCWCSU Expenses claims Personal data None - Identifiable Electronic Cloud storage Password protected network

drive/system

SEL expenses system 21 to 100 Monthly Staff Expenses claim Encrypted secure email

service

Encrypted (approved) Within UK 4 2 8 Manual calculations of expenses if necessary and disaster

recovery plan on CSU systems



authority

SLA in place a) CCGs - NHS Act 2006. N/A N/A

F03 Finance Oracle/IFSE (suppliers send

invoices to SBS who then

upload to Oracle

In-flow CCG Finance Team Invoices for CHC patients on

Broadcare

Personal data Pseudonymised Electronic NHS shared drive None Less than 5 Daily Invoice payment Within software solution Password protected All invoices are viewed through Oracle by approved users Within UK 4 1 #REF! #REF! #REF! #REF! #REF! #REF! #REF!

F04 Finance CCG Finance Team Out-flow Oracle/IFSE through Controlled

Environment for Finance

(CEfF)

Invoices (once validated by

SCWCSU)

Personal data Pseudonymised Electronic NHS shared drive None Less than 5 Daily Invoice payment Within software solution Password protected All invoices are viewed through Oracle by approved users Within UK (e) Performance of a task in the public


authority

(c) Legal Duty a) CCGs - NHS Act 2006.

b) NHS Trusts: National Health Service and


Irrelevent to CCG Comment: Is this not done by CSU for CCG?

No legal basis for CCG to access PID for this

even though this falls within section 251. no PID

F05 Finance SBS (via Oracle) In-flow CCG Finance Team Suppliers information in order to pay

them for commissioned services e.g.

bank account details

Commercial

data

None - Identifiable Electronic Specific software solution - Oracle Specific software solution Password protected network

drive/system

Password protected files 1001 plus Daily Payment of suppliers NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 1 (e) Performance of a task in the public


authority

(c) Legal Duty a) CCGs - NHS Act 2006.

F06 Finance SCWCSU (Oxford Health

send to the CSU)

In-flow CCG Finance Team Financial forecasts or CHC patients

on Broadcare

Personal data Pseudonymised Electronic Broadcare number only - record level report. These reports sit outside Oracle. NHS shared drive None 1001 plus Monthly Reconciliation between

provider claims for payments

and forecasts

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 1

F07 Finance CCG Finance Team Out-flow NHS England Transforming care inpatient sitrep and

projections -sent to NHS England:

relating to patients that sit in Spec

Com beds with a view to moving them

into community from low secure beds.

Personal data None - Identifiable Electronic Patient name, NHS number. The request comes from them, we complete, and sent it back. The

programme finishes 31 March 2019 but there may be a further need for reporting after. This relates

to specialist commissioning learning disability beds. Inflow in a blank template. Data to complete the

template comes from integrated commissioning. We complete it instead of them because of funding

flow. Transfer of patients acute to community costs are paid by the CCG. This is an NHS England

requirement to link patients in spec com beds to community repartriation. Transforming care lead

Ruth Kenyon in NHSE is link

NHS shared drive Restricted Access Folder Restricted Access 101 to 1000 Monthly NHSmail to NHSmail NHSmail [secure] encryption Within UK (e) Performance of a task in the public


authority

(c) Legal Duty Statutory Requirements a) CCGs - NHS Act 2006

b) NHS E - NHS Act 2006

Comment: find the statute under common law.

F08 Finance SCWCSU Human

Resources (CSU has inflow

and outslow with Salisbury

NHS FT as payroll provider)

In-flow CCG Finance Team PAYE/Pensions/Payroll - payroll

reports

Personal data None - Identifiable Electronic Bank account numbers, name, national insurance number (address not held as this sits in ESR) NHS shared drive None Restricted Access 101 to 1000 Monthly Ensure accuracy of payroll and

pension records

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 1 (b) Performance of a contract to which

a Data Subject is party to

(c) Legal Duty a) CCGs - NHS Act 2006 Comment: What is the statute that allows for this

under Common Law?

F09 Finance NHS Pensions

Agency/SCWCSU

In-flow CCG Finance Team PAYE/Pensions/Payroll (Greenbury

reporting requirement)

Personal data None - Identifiable Electronic This relates to CCG office holders (i.e. senior managers, member GPs) and their pension

entitlements. Other staff can look at pension entitlements through Electornic Staff Record (ESR).

Name, DOB, NI number, membership number, date joined scheme.

NHS shared drive Restricted Access Folder Restricted Access 101 to 1000 Monthly Statutory reporting

requirements on pay and

pensions




under Common Law?

F10 Finance CCG Finance Team Out-flow NHS Pensions

Agency/SCWCSU

PAYE/Pensions/Payroll (Greenbury

reporting requirement)

Personal data None - Identifiable Electronic This relates to CCG office holders (i.e. senior managers, member GPs) and their pension

entitlements. Other staff can look at pension entitlements through Electornic Staff Record (ESR).

Name, DOB, NI number, membership number, date joined scheme.

NHS shared drive Restricted Access Folder Restricted Access 101 to 1000 Monthly Statutory reporting

requirements on pay and

pensions




under Common Law?

CM01 Community Models of

Care

SCWCSU Business

Intelligence

In-flow CCG Commissioning Team Care Homes Dashboard (origin

Intelligence Point)

Personal data Pseudonymised Electronic NHS shared drive None 1001 plus Monthly Monitoring of non-elective

admissions and ambulance

admissions linked to care home

patients



authority

a) CCGs - NHS Act 2006 Comment: What is the legal basis for the CCG

to share thisdata? Is SUS data involved? DSA in

place?


Care

SCWCSU Out-flow Buckinghamshire County

Council

Care Homes Dashboard (origin

Intelligence Point)

Personal data Pseudonymised Electronic This is done adhoc when the county council ask for it NHS shared drive None 1001 plus Monthly Monitoring of non-elective



patients



authority

a) CCGs - NHS Act 2006 Comment: What is the legal basis for the CCG

to share thisdata? Is SUS data involved? DSA in

place?


Care

SCWCSU Business

Intelligence

In-flow CCG Commissioning Team Patients Died in Hospital report Personal data Pseudonymised Electronic NHS shared drive None 101 to 1000 Monthly Monitoring of non-elective



patients



authority

Data Processing agreement in place with CSU.

Also DARs in place with NHSD


Care

CSU Contracts Team In-flow CCG Commissioning Team End of life contracts tracker Other N/A (commercial

information)

Electronic NHS shared drive None 21 to 100 When required Record of contract

arrangements with end of life

providers

email within NHS NHSmail Within UK 1 1 1 (f) Legitimate Interests (note public

authorities can only rely on this in

exceptional circumstances)CM05 Community Models of

Care

Oxford Health In-flow CCG Commissioning Team CHC Packages of care - high cost

package request

Special

Categories of

personal data

Pseudonymised Electronic Broadcare number NHS shared drive Restricted Access Folder Less than 5 When required Agreement to fund packages of

care

NHSmail to NHSmail Not applicable - must add comment No PID Within UK 1 1 1 (e) Performance of a task in the public


authority

a) CCGs - NHS Act 2006


Community Care Act 1990

NHS standard contract in place.


Care

CCG Commissioning Out-flow Oxford Health CHC Packages of care - high cost

package request

Special

Categories of

personal data

Pseudonymised Electronic Broadcare number NHS shared drive Restricted Access Folder Less than 5 When required Agreement to fund packages of

care

NHSmail [secure] encryption Not applicable - must add comment No PID Within UK 1 1 1 (e) Performance of a task in the public


authority


informed)




NHS standard contract in place.


Care

Oxford Health In-flow CCG Commissioning Team (for

exceptions panel)

CHC Exceptions panel meetings -

case history and related papers

Special

Categories of

personal data

None - Identifiable Electronic Full details to facilitate complex case review. Password protected files. NHS shared drive Restricted Access Folder Less than 5 When required Agreement to fund packages of

care



authority


informed)




IG Comment: The panel does not need full PID.


Care

CCG Commissioning Team

(for exceptions panel)

Out-flow Oxford Health CHC Exceptions panel meetings -


Special

Categories of

personal data

None - Identifiable Electronic Full details to facilitate complex case review. Password protected files. NHS shared drive Restricted Access Folder Less than 5 When required Agreement to fund packages of

care



authority


informed)




IG Comment: The panel does not need full PID.


Care

CCG Commissioning Team In-flow CCG CHC Exceptions Panel

(includes outside bodies)



Personal data None - Identifiable Electronic Full details to facilitate complex case review. Password protected files. NHS shared drive Restricted Access Folder Less than 5 When required Agreement to fund packages of

care

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 2 8


Care

CCG Commissioning Team Out-flow CCG CHC Exceptions Panel

(includes outside bodies)




care

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 1 8 (a) Consent (implied, explicit,

informed)




IG Comment: no legal basis as the CCG does

not undertake CHC function.


Care

CCG Commissioning Team Out-flow Buckinghamshire County

Council




care

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 1 8 (a) Consent (implied, explicit, informed) a) CCGs - NHS Act 2006

b) NHS Trusts: National Health

Service and Community Care Act

1990




Care

Relevant provider


NHS Trust

Frimley Health NHS Trust

Any other provider relevant

to Buckinghamshire patients

In-flow Named GPs appointed to

clinically review applications

for funding (through MH Virtual

Panel)

Patient notes for purposes of clinical

assessment in advance of mediation

(which may occur if there is a

difference of opinion over tariff

charging arrangements vs level of

clinical care provided)

Personal data None - Identifiable Electronic NHSMail Password protected files Less than 5 When required Agreement to fund packages of

care

NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 1 8 (a) Consent (implied, explicit, informed) a) CCGs - NHS Act 2006

b) NHS Trusts: National Health

Service and Community Care Act

1990



IC01 Integrated

Commissioning

Buckinghamshire County

Council e.g. social worker

In-flow CCG/BCC Integrated

Commissioning Team

Child and adult MH

treatment/placement approval requests

(including Section 117)

Special

Categories of

personal data

None - Identifiable Electronic Name, DOB and NHS number, current residence/address, potential future address, diagnosis of

need. This relates only to out of area section 117 placement where there may be negotiation of

responsibility for funding (which may be split between area where patient is registered and area

where patient is being treated/resident).

File sharing platform Restricted Access Folder BCC shared drive - CCG

escalations for decision only on

email

0 to 4 Monthly Funding approval for treatment

packages outside of contracts

Encrypted secure email

service

Encrypted (approved) most communication through buckscc.gov.uk Within UK 3 2 6 Separate letter requests for funding if routine systems were

unavailable. All commissioned providers expected to have

business continuity plans to cover system failure



authority



and services


informed)

a) CCGs - NHS Act 2006 Individual contract in place

Explicit consent needed under common law.

IC02 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow Buckinghamshire County


Child and adult MH

treatment/placement approval requests

(including Section 117)

Special

Categories of

personal data


need. This relates only to out of area section 117 placement where there may be negotiation of

responsibility for funding (which may be split between area where pa

File sharing platform Restricted Access Folder BCC shared drive plus CCG

shared drive and CCG escalations

for decision only on email

0 to 4 Monthly Funding approval for tretament



service






authority



and services


informed)



IC03 Integrated

Commissioning

A provider (e.g. South

London and Maudsley,

Oxford Health)


Commissioning Team

Child and adult, mental health, learning

disabilities, autism and physical

disabilities funding

application/approval requests

Special

Categories of

personal data


need







service






authority



and services


informed)



IC04 Integrated

Commissioning

CCG/BCC Joint

Commissioning Team

Out-flow A provider (e.g. South London

and Maudsley, Oxford Health)





Special

Categories of

personal data


need







service






authority



and services


informed)



IC05 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

In-flow Named GPs appointed to



Panel)





Special

Categories of

personal data


need




0 to 4 When required Funding approval for treatment



service






authority



and services


informed)




to delegate such powers to CCGs.IC06 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow Named GPs appointed to



Panel)





Special

Categories of

personal data


need




DO THE EMAILS GET DELETED




service






authority



and services


informed)





Some of the invoices will relate to schedules. Broadcare generates a care home schedule which

shows all Individual Patient Agreements (i.e. contracts) for all patients with the home, with subsequent

invoives cross referenced to the schedule. The CHC team from Oxford Health send the schedule only

to the homes. We don't obtain a copy. Each schedule has a reference so the invoives cross

reference to the schedule. No identifiers on the invoice, only on the schedule. However there are

circumstances where invoices are not on the schedule, and so may quote initials, IPA number or

Broadcare number. This is likely identifiable without access to the systems to which they relate

(which the CCG does not have). Invoices are sent to SBS and stored there, and we sign off through

Oracle to approve. Scanned PDF invoices may be downloaded adhoc for reconciliation purposes.

SBS should reject any invoice with patient identifiable on, but this may not always be accurate. The

contract with Oracle is held by NHS England. Our Controlled Environment for Finance is within the

SCWCSU

(1) Suppliers send invoices to SBS

(2) SBS scan to Oracle. Containing PID should be rejected

(3) SBS assign invoices to user work flows (in CCGs if run in-house or CSU's

(4) Provider sends backing PID to Controlled Environment for Finance (in SCSCU for us)

(5) SCWCSU validates

26.04.19

01494 586771

[email protected]

Telephone:

Who

Russell Carpenter, Data Protection Officer

Where WhenWhat How Additional InformationLegal Basis of Data Flow

Specialist Nurse: This is so support clinical management of patients - clinical support and education

through virtual clinics and group sessions. Review of patient details to identify clinical needs.

Transformation Support Officers: Reviewing practice process in relation to patient coding e.g.. type 1

rather than type 2 etc. which might involve patient record review, but seen only within the member

practice premises

13/06/2019

mailto:[email protected]




Last Updated:

BCCG Contact:

Email:

26.04.19

01494 586771

[email protected]

Telephone:

Who


Where WhenWhat How Additional InformationLegal Basis of Data FlowIC07 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

In-flow CCG MH Virtual Panel Child and adult, mental health, learning




Special

Categories of

personal data


need







service






authority



and services


informed)


IC08 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow CCG MH Virtual Panel Child and adult, mental health, learning


disabilities funding application

/approval requests

Special

Categories of

personal data


need







service






authority



and services


informed)


IC09 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

In-flow CCG Complex Needs Panel

(only individuals CCG and

BCC integrated commissioning

team)




/approval requests (where there are

complex needs)

Special

Categories of

personal data


need, sometimes Broadcare number, sometimes sibling information which may identify them as well







service






authority



and services


informed)


IC10 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow CCG Complex Needs Panel

(only individuals CCG and

BCC integrated commissioning

team)




/approval requests (where there are

complex needs)

Special

Categories of

personal data









service






authority



and services


informed)


IC11 Integrated

Commissioning

NHS England In-flow CCG/BCC Integrated

Commissioning Team

National Care & Treatment review

programme (people with learning

disability and/or autism)

Special

Categories of

personal data









service






authority



and services


informed)

Is there a data sharing/contract in

place as part of the flow?


b) NHSE - NHS Act 2006

c) Local Authorities;

1. Local Govevern Act 1974

2. Children Act 1999.

3. Children Act 2004

4. Care Act 2014.IC12 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow NHS England National Care & Treatment review

programme (people with learning

disability and/or autism)

Special

Categories of

personal data

Pseudonymised Electronic Name, DOB and NHS number, current residence/address, potential future address, diagnosis of








service






authority



and services


informed)


b) NHSE - NHS Act 2006

c) Local Authorities;

1. Local Govevern Act 1974

2. Children Act 1999.

3. Children Act 2004

4. Care Act 2014.IC13 Integrated

Commissioning

Providers / other agencies

involved in care delivery /

BCC


Commissioning Team

Invoices for agreed placements Personal data None - Identifiable Electronic This is for purpose of fraud prevention. The report corresponding to the intervention would be sent by

email and stored on a shared drive. This could include backing data.

Non-NHS storage solution Password protected network

drive/system

Password protected files Less than 5 When required Invoice payment Encrypted secure email

service






authority

(c) Legal Duty What legal statute under common

law confidentiality is relied upon?

IC14 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow Providers / other agencies

involved in care delivery / BCC

Invoices for agreed placements Personal data None - Identifiable Electronic This is for purpose of fraud prevention. The report corresponding to the intervention would be sent by

email and stored on a shared drive. This could include backing data.

Non-NHS storage solution Password protected network

drive/system


service






authority



IC15 Integrated

Commissioning


involved in care delivery /

BCC


Commissioning Team

Invoices for agreed placements Personal data None - Identifiable Electronic This is for purpose of fraud prevention. The invoice itself with be paid through Oracle. Sometimes the

invoice includes patient name.


drive/system


service

Password protected Within UK 3 2 6 Separate letter requests for funding if routine systems were





authority



IC16 Integrated

Commissioning

CCG/BCC Integrated

Commissioning Team

Out-flow Providers / other agencies

involved in care delivery / BCC

Invoices for agreed placements Personal data None - Identifiable Electronic This is for purpose of fraud prevention. Specific software solution Password protected network

drive/system


service

Password protected Within UK 3 2 6 Separate letter requests for funding if routine systems were





authority



IC17 Integrated

Commissioning

Providers (e.g. South

London and Maudsley NHS

trust)


Commissioning Team

Care Programme Approach (CPA) -

records of discussions in relation to

treatment packages

Personal data None - Identifiable Electronic provider may send: (1) a report to show patient progress against the package funded by the CCG (2)

requests for one to one care with request for CCG to fund

Non-NHS storage solution Restricted Access Folder Less than 5 When required Package evaluation Non-secure email Not applicable - must add comment We have little control when providers don’t use secure

means to send this data

Within UK 4 2 8 Funding requests likely to be re-submitted by providers by post

if not electronically

IC18 Integrated

Commissioning

Providers In-flow BCC Integrated

Commissioning Team

Invoices for out of county Looked

After Children assessments

Personal data None - Identifiable Electronic Stored on Oracle as the finance system Specific software solution Password protected network

drive/system

Less than 5 When required payment for out of area Looked

After Children assessments

Within software solution Password protected Within UK 3 1 3 (c) Controller has a legal obligation (f) Legal claims, (c) Legal Duty n/a statutory guidance statutory guidance statutory guidance

PM01 PMO SCWCSU (originating from

NHS Digital)

In-flow CCG staff (named Intelligence

Point users plus to all staff

through shared folder access)

Care Homes Report (through

Intelligence Point)

Personal data Pseudonymised Electronic Specific software solution Password protected network

drive/system

Intelligence Point 1001 plus Monthly Within software solution Password protected Within UK 2 2 4


NHS Digital)




Urgent Care Dashboard (through

Intelligence Point)


drive/system



NHS Digital)




Paediatric Dashboard (through

Intelligence Point)


drive/system



NHS Digital)




Over 75 Admissions Report (through

Intelligence Point)


drive/system



NHS Digital)




Falls Age 65+ vs Bucks Reg Pop

(through Intelligence Point)


drive/system



NHS Digital)




QIPP Monthly Report (through

Intelligence Point)


drive/system



NHS Digital)




Excess Bed Days report (through Intelligence Point)Personal data Pseudonymised Electronic Specific software solution Password protected network

drive/system



NHS Digital)




End of Life Report (through

Intelligence Point)


drive/system

Intelligence Point 101 to 1000 Monthly Within software solution Password protected Within UK 2 2 4


NHS Digital)




ICS Dashboard Bucks CCG level

(through Intelligence Point)


drive/system



NHS Digital)




ICS Dashboard for Each Locality (7

reporst one for each locality) (through

Intelligence Point)


drive/system



NHS Digital)




GP Referrals Dashboard (through

Intelligence Point)

Personal data Pseudonymised Electronic SLAM/Referral files Specific software solution Password protected network

drive/system


PM12 PMO SCWCSU (SUS originating

from NHS Digital, primary

care data originating from

pratices as data controllers

via SCWCSU)

In-flow CCG staff (named users of IPA

tool only)

Risk stratification and population

health management

Personal data Anonymous Electronic Specific software solution Password protected Insight Population Analytics

(commissioned by CCG)

1001 plus Monthly Population Health management Within software solution Password protected Within UK (Bristol) 3 2 6

PM13 PMO CCG staff Out-flow Buckinghamshire County

Council (specifically approved

by the CCG SIRO)


health management



1001 plus Monthly Population Health management Within software solution Password protected Within UK (Bristol) 3 2 6 Wayne Thompson has a confidentiality

agreement [G:\AVCCG CCCG

SCWCSU\Statutory Documents\Information

Governance\Data Protection Toolkit 18-

19\Population Health Management] "Wayne

Thompson 8 June 2017"PM14 PMO CCG staff (BCC staff on

honorary contracts)

Out-flow GP Member practices

plus:

Various audiences:

PHM delivery board

Locality Clincians and localities

(through profiles)

Commissioners

Providers


health management: Statistical graphs

from the above data sets



1001 plus Monthly Population Health management Within software solution Password protected Within UK (Bristol) 2 2 4 Shakiba Habibula and Tiffany have honorary

CCG Contracts [G:\AVCCG CCCG

SCWCSU\Statutory Documents\Information

Governance\Data Protection Toolkit 18-

19\Population Health Management\Honorary

Contract] "Dr Shakiba Habibula Honorary

Contract (signed)" "Honorary Contract Dr T

Burch"

PM15 PMO SCWCSU (including

DSCRO) on behalf of CCG

Out-flow Any named provider asked to

analyse (but not process) a

dataset sourced from SUS,

HES, or any other

commissioning data set at

patient level e.g. Sollis,

Catapult, Cap Gemini, PWC

Commissioning Data Set analysis (no

further processing), such as:

1. Localities profiles

2. Cancer activity

3. Population Health Management

Personal data Pseudonymised Electronic NHS shared drive None None 101 to 1000 Bi-monthly NHSmail to NHSmail NHSmail [secure] encryption Data Levels

(1 Record level (identifiable)

(2) Record level (Pseudonymised)

(3) Aggregated (low number supressed)

(4) Anonymised

Note: Under new GDPR/Data Security and Protection

Toolkit requirements, only anonymised flows do not

require DPIA, Information Sharing Agreement (Tier 2)

and Data flow mapping entry. All other flows require this

detail completing unless there is exemption (point 1

above)

Data Sets Utilised

COMMISSIONING DATA SETS NATIONAL FLOWS

(1) SUS (Invoice Validation and Risk Stratification)

(Commissioning)

(2) Local Provider Data

(3) Ambulance Local Provider Data

(4) Community Local Provider Data

(5) Mental Health Local Provider Data

(6) Population Data Local Provider Data

(7) Mental Health Services Data Set

(8) Improving Access to Psychological Therapies

(2016/2017)

(9) Maternity Services

(10) Mental Health Learning Disability Data Set

(11) Children and Young People’s Health

(12) Diagnostic Imaging Dataset

Will vary according to company

asked to analyse data

3 2 6 Not obvious that there is personal data in the files. We have

hisotrically used a template which requiries patient numbers, but

this template can be amended

(b) Performance of a contract to which




and services


informed)

DT05 Digital SCWCSU (originating from

NHS Digital)

In-flow CCG and GP Staff Insight Population Analytics (IPA) Electronic Secured by supplier in UK 2 0 (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and services

(c) Legal Duty Specific Information Sharing

Agreement

DT06 Digital Member GP practices Out-flow SCWCSU (originating from

NHS Digital)

Insight Population Analytics (IPA) Electronic Secured by supplier in UK 2 0 (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and services

(c) Legal Duty Specific Information Sharing

Agreement

DT07 Digital In-flow Sharon Hanley Looking at connections looking at a

live patient for graphnet ask NHS

2 (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and servicesDT01 Digital Graphnet / System C (as

LHCRE provider)

In-flow CCG staff Local Health and Care Record

Exemplar (LCHRE)

Personal data None - Identifiable Electronic Microsoft Azure UK (Public Cloud) Cloud storage Password protected network

drive/system

When required Direct care Within software solution Encrypted (approved) transfer is API (typically Health Level 7 - HL7) Data is in Azure UK. Data

Processor is UK based

4 1 4 RTO / RPO in contract (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and services

(c) Legal Duty TBD TBD TBD TBD

DT02 Digital SCWCSU (originating from

NHS Digital)

Out-flow CCG staff Local Health and Care Record

Exemplar (LCHRE)

Personal data Pseudonymised Electronic Microsoft Azure UK (Public Cloud) Cloud storage Password protected network

drive/system

When required Direct care Within software solution Encrypted (approved) transfer is API (typically Health Level 7 - HL7) Data is in Azure UK. Data

Processor is UK based

4 1 4 RTO / RPO in contract (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and services

(c) Legal Duty BOB STP Framework, Tier 1 and

Tier 2

TBD TBD TBD

QS01 Quality and

Safeguarding

Relevant provider


NHS Trust




In-flow CCG MRSA bacteraemias Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Only quality team can access

restricted folder

1001 plus When required Need to contact relevant

providers to identify any

learning as a result of post

infection reviews

NHSmail to NHSmail NHS Secure file transfer within UK 4 1 4 (e) Performance of a task in the public


authority



and services

(b) Public Interest Required to do this by NHSI As above As above As above

QS02 Quality and

Safeguarding

Infection Prevention &

Control Lead Nurse

Out-flow GP, care home, acute trust

(Buckinghamshire Healthcare

NHS Trust


Any other provider relevant to

Buckinghamshire patients)

MRSA bacteraemias Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder only quality team can access

restricted folder

21 to 100 When required Need to contact relevent



infection reviews



authority



and services

(b) Public Interest Required to do this by NHSI -see

guidance link in next column

National requirement from NHSI -

https://improvement.nhs.uk/documents/2512/MR

SA_post_infection_review_2018_changes.pdf







QS03 Quality and

Safeguarding

Relevant provider:


NHS Trust




In-flow CCG Cdifficile incidents Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Only quality team can access

restricted folder

101 to 1000 Weekly Need to contact relevent



infection reviews

NHSmail to NHSmail NHS Secure file transfer There may be occassional paper returns by post Within UK 4 1 4 (e) Performance of a task in the public


authority



and services

(b) Public Interest Required to do this by NHSI As above As above As above

QS04 Quality and

Safeguarding


Control Lead Nurse

Out-flow GP, care home, acute trust

(Buckinghamshire Healthcare

NHS Trust


Any other provider relevant to

Buckinghamshire patients)

Cdifficile incidents Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder only quality team can access

restricted folder

1001 plus Weekly Need to contact relevent



infection reviews

NHSmail to NHSmail NHS Secure file transfer Within UK 4 1 4 (e) Performance of a task in the public


authority



and services



Cdifficile objective, requirement from NHSI - we

also have to adjudicate on whether acute trust

cases to determineif penalties are to be applied

https://improvement.nhs.uk/documents/808/CDI

_objectives_18_19_FINAL_Oct2018.pdf











QS05 Quality and

Safeguarding

Relevant provider In-flow CCG Gram-negative bloodstream infections

(GNBSI) - aka e.coli

Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Only quality team can access

restricted folder

21 to 100 Monthly Not all cases will be followed

up, limited cohort



authority



and services

(b) Public Interest required to do this by NHSI As above As above As above

QS06 Quality and

Safeguarding


Control Lead Nurse

Out-flow GP, care home, acute trust Gram-negative bloodstream infections

(GNBSI) - aka e.coli


restricted folder

101 to 1000 Monthly NHSE requirement to folow up

cases and identify learning and

part of the Quality Premium



authority



and services



Requirement from NHSI

https://www.england.nhs.uk/wp-

content/uploads/2018/04/annx-b-quality-

premium-april-18.pdf




premium-april-18.pdf




premium-april-18.pdfQS07 Quality and

Safeguarding

Public Health England In-flow CCG Other (e.g. escalations of complex

cases)


restricted folder

Less than 6 When required There can be occasional cases

where patient is dicussed and

needs to be identified. PHE

lead on this and only provide

PII where necessary - in most

cases the processis carried out

on an anonymised basis


service

Encrypted (approved) This always comes from PHE they are not on NNHS mail

but I know their email is secure

Within UK 4 1 4 (e) Performance of a task in the public


authority

(i) Public health, (b) Public Interest Required to be involved with this for

public health reasons and protection

of patients health

Public health legislation might cover some of this Public health legislation might cover some of this Public health legislation might cover some of this

QS08 Quality and

Safeguarding

Public Health England In-flow Infection Control Lead Nurse HCAI DCS (Data Capture System): all

healthcare acquired infections


restricted folder

21 to 100 Weekly To monitor cases, for liaison

and advice to professionals

caring for pt, to identify

learning and trends for

prevention of disease in future

SFTP NHS Secure file transfer Access to system is also password protected Within UK 4 1 4 (e) Performance of a task in the public


authority



and services

(b) Public Interest For column Z you could also choose

public health becuase it is about

preventing infections in other people

as well

QS09 Quality and

Safeguarding

Nurses /GPs in GP

practices/care homes to

prompt case investigation

(e.g. community acquired C

Diff)

In-flow Infection Control Lead HCAI DCS (Data Capture System): all

healthcare acquired infections; Case

review information; used in discussion

of health economy wide C difficile

cases at Buckinghamshire Infection

Control Committee, prompted by data

held on HCAI DCS (Data Capture

System)


restricted folder

Less than 6 Weekly To monitor cases, for liaison

and advice to professionals

caring for pt, to identify

learning and trends for

prevention of disease in future

SFTP NHS Secure file transfer Access to system is also password protected Within UK 4 1 4 (e) Performance of a task in the public


authority



and services

(b) Public Interest For column Z you could also choose

public health becuase it is about

preventing infections in other people

as well

QS10 Quality and

Safeguarding


Control Lead Nurse

Out-flow PHE, GP, care home, acute

trust

other Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Only quality team can access

restricted folder

1001 plus When required As above but very rare that we

would need to send data out -

more likely that we will be

receiving



authority



of patients health


QS11BOTH Quality and

Safeguarding

University of Bristol In-flow CCG Quality Team LEDR programme. LEDR database

and secure local folders access

restricted


restricted folder

6 to 20 When required Cases managed through ECDOP system if under 18. 3 3 9 (e) Performance of a task in the public


authority



of patients health



Safeguarding

CCG Quality Team Out-flow University of Bristol LEDR programme. LEDR database

and secure local folders access

restricted


restricted folder

101 to 1000 When required Cases managed through ECDOP system if under 18. 3 3 9 (e) Performance of a task in the public


authority



of patients health



Safeguarding

Local Authority solicitors etc In-flow Safeguarding Leads Court of Protection judgements

(judicial deprivation of liberty

safeguards)

Personal data None - Identifiable Electronic NHSMail None To be transferred to restricted

safeguarding folder

Less than 6 When required Court of protection judgements:

for information only as we

commission the CHC team to

ensure CHC team is acting

upon actions specified

Royal Mail (special or

registered post)

Royal Mail (special or registered

post)

Within UK 5 4 20 We wont know if we were not in receipt, so there is no further

mitigations we can apply.



authority



of patients health



Safeguarding


involved in the complex case

In-flow Safeguarding Leads Escalations of complex cases (Adults

and Children) e.g. child sexual

exploitation cases, FGM cases,

modern slavery, trafficking

Personal data None - Identifiable Electronic information received on a case by case basis NHS shared drive Restricted Access Folder Less than 6 When required responding to queries NHSmail to NHSmail NHS Secure file transfer Within UK 3 1 3 (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and services

(c) Legal Duty n/a


Safeguarding

Thames Valley Police In-flow Safeguarding Leads Domestic Homicide Reviews (always

adults, sometimes children)

Personal data None - Identifiable Electronic NHSMail Password protected files 1001 plus When required Management of reviews NHSmail to NHSmail NHSmail [secure] encryption Within UK 4 2 8 The initial request from domsetic homicode department comes

to LA, who request to partners to join the review. LA would

escalate to CCG Accountable Officer if there is a breakdown in

communication

The review will follow the Statutory Guidance for

Domestic Homicide Reviews under the Domestic

Violence, Crime and Victims Act 2004 which

came into force on 13th April 2011 and was

revised for all notifications from 1 August 2013

and further revised in December 2016.


Safeguarding

Home Office/Joint Terrorism

Analysis Centre (JTAC)

In-flow Safeguarding Leads Prevent and modern slavery related

data (both)

Special

Categories of

personal data

None - Identifiable Electronic Informationtion from Home Office/JTAC about security threats NHSMail Password protected network

drive/system

Less than 6 When required Management of local security

threats

NHSmail to NHSmail NHSmail [secure] encryption Within UK 5 4 20 Counter-Terrorism Local Profile lead would always be default for

contact from Joint Terrorism Action Committee (JTAC)


Safeguarding

Safeguarding Leads Out-flow Providers / other agencies

involved in the complex case

Escalations of complex cases (Adults

and Children) e.g. child sexual

exploitation cases, FGM cases,

modern slavery, trafficking

Personal data None - Identifiable Electronic information received on a case by case basis NHSMail Restricted Access Folder Less than 5 When required responding to queries NHSmail to NHSmail NHS Secure file transfer Within UK 3 1 3 (c) Controller has a legal obligation (h) Medical and Health diagnosis, treatment or


and services

(c) Legal Duty n/a

QS18CH Quality and

Safeguarding



In-flow Safeguarding Leads Serious Case Reviews (via

Safeguarding Children Sub-Group or

Child Death Overview Panel)

Personal data None - Identifiable Electronic serious case reviews are anonymised before the report is published NHS shared drive Restricted Access Folder Less than 5 When required statutory requirement NHSmail to NHSmail Password protected Cases managed through ECDOP system if under 18. Within UK 2 1 2 (c) Controller has a legal obligation (c) Vital interests, (c) Legal Duty n/a legislation required legislation required legislation required

QS19CH Quality and

Safeguarding



In-flow Safeguarding Lead Children,

BCC Integrated

Commissioning Team

Looked After Children including health

assessments and related invoices

Personal data None - Identifiable Electronic information also received via post NHS shared drive Restricted Access Folder Restricted Access folders are

both in CCG and BCC

Less than 5 When required statutory guidance dictates

CCG requires the information

NHSmail to NHSmail NHSmail [secure] encryption Also stored on county council N drive Within UK 3 1 3 (c) Controller has a legal obligation (f) Legal claims, (c) Legal Duty n/a statutory guidance statutory guidance statutory guidance

QS20CH Quality and

Safeguarding

Home Office and District

Councils

In-flow Designated Nurse

Safeguarding Children and

Looked After Children

Refugee Resettlement Personal data None - Identifiable Electronic We house refugees from Syria mainly NHS shared drive Restricted Access Folder Less than 5 When required NHSmail to NHSmail NHSmail [secure] encryption Within UK 3 1 3 (c) Controller has a legal obligation (f) Legal claims, (c) Legal Duty n/a statutory guidance statutory guidance statutory guidance

QS21SA Quality and

Safeguarding



In-flow Safeguarding Adult Lead Safeguarding Adult Reviews (via

Safeguarding Adult Review sub-group)

Personal data None - Identifiable Electronic safeguarding adult reviews are anonymised before the report is published NHS shared drive Restricted Access Folder Less than 5 When required statutory requirement (through

secure messaging system

Egress Switch)

Within software solution Password protected Within UK 2 1 2 (c) Controller has a legal obligation (c) Vital interests, (c) Legal Duty n/a legislation required legislation required legislation required

QS22 Quality and

Safeguarding

SCWCSU In-flow CCG Quality Team Complaints/Patient Queries. Could

also include primary care disputes.

Personal data None - Identifiable Electronic SCWCSU route complaint responses to patients NHSMail Password protected network

drive/system

0 to 4 Daily Complaints Process NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

QS23 Quality and

Safeguarding

CCG Quality Team Out-flow SCWCSU Complaints/Patient Queries. Could

also include primary care disputes.

Personal data None - Identifiable Electronic SCWCSU route complaint responses to patients NHSMail Password protected network

drive/system

0 to 4 Daily Complaints Process NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

QS24 Quality and

Safeguarding

CCG member GP practices In-flow CCG Quality Team Clinical Concerns Personal data None - Identifiable Electronic Adhoc soft intelligence on quality and performance issues with commissioned providers experienced

in primary care

NHS shared drive Restricted Access Folder 5 to 50 Monthly Queries from GPs Post NHSmail [secure] encryption Within UK 0

QS25 Quality and

Safeguarding

CCG Quality Team Out-flow CCG member GP practices Clinical Concerns Personal data None - Identifiable Electronic Adhoc soft intelligence on quality and performance issues with commissioned providers experienced

in primary care

NHS shared drive Restricted Access Folder 5 to 50 Monthly Answer GP query email within NHS NHSmail [secure] encryption Within UK 0

QS26 Quality and

Safeguarding

Serious Incident to the

Strategic Executive

Information System (StEIS)

In-flow CCG Quality Team Serious incident management Personal data None - Identifiable Electronic Date of birth and gender Specific software solution Password protected network

drive/system

Less than 5 When required serious incident management -

investigation and learning

NHSmail to NHSmail NHSmail [secure] encryption Within UK

QS27 Quality and

Safeguarding

CCG Quality Team Out-flow Serious Incident to the

Strategic Executive Information

System (StEIS)

Serious incident management Personal data None - Identifiable Electronic Date of birth and gender. Specific software solution Password protected network

drive/system

Less than 5 When required serious incident management -

investigation and learning

NHSmail to NHSmail NHSmail [secure] encryption Within UK

QS28 Quality and

Safeguarding



In-flow Safeguarding Adults Lead safeguarding alerts Personal data None - Identifiable Electronic The types of a safeguarding alert are potentially numerous and not necessarily easy to categorise. A

safeguarding alert is generally defined as information which indicates a risk to an individual or group.

NHS shared drive Restricted Access Folder 0 to 4 Daily To allow investigation System outside NHS Encrypted (approved) This flow involves the use of GCSX secure email address

at BCC

Within UK 0

QS29 Quality and

Safeguarding

Safeguarding Adults Lead Out-flow Buckinghamshire County


safeguarding alerts Personal data None - Identifiable Electronic The types of a safeguarding alert are potentially numerous and not necessarily easy to categorise. A

safeguarding alert is generally defined as information which indicates a risk to an individual or group.

NHS shared drive Restricted Access Folder 0 to 4 Daily To allow investigation System outside NHS Encrypted (approved) This flow involves the use of GCSX secure email address

at BCC

Within UK 0

QS30 Quality and

Safeguarding

NHS England In-flow CCG Primary Care Team GMC Notifications / NHS England

Performance Advistory Group

Personal data None - Identifiable Electronic GMC Number/name NHS shared drive Restricted Access Folder Less than 5 When required Primary Care Commissioning NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

QS31 Quality and

Safeguarding

CCG Primary Care Team

(Local Area Designated

Officer)

Out-flow NHS England GMC Notifications / NHS England

Performance Advistory Group

Personal data None - Identifiable Electronic Name of individual (e.g. GP/practice nurse) and pracrice they work for - we have a concern with a

request to review

NHS shared drive Restricted Access Folder Less than 5 When required Primary Care Commissioning NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

QS32 Quality and

Safeguarding

CCG staff In-flow CCG Freedom to Speak Up

Guardians

Staff information associated with

whistleblowing concerns/investigations

Personal data None - Identifiable Electronic Name of individual (e.g. GP/practice nurse) and pracrice they work for - we have a concern with a

request to review

NHS shared drive Restricted Access Folder Less than 5 When required Primary Care Commissioning NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

SOURCES: COMMISSIONING DATA SETS:

SUS (Commissioning)

Local Provider Data

Ambulance Local Provider Data

Community Local Provider Data

Mental Health Local Provider Data

Population Data Local Provider Data

Mental Health Services Data Set

Improving Access to Psychological Therapies (2016/2017)

Maternity Services

Mental Health Learning Disability Data Set

Children and Young People’s Health

Diagnostic Imaging Dataset

These flows are the outputs of the DARS agreement signed

between CCG and NHS Digital to describe processing

arrangements for SUS and Commissioning Data Set sources.

SUS data source (from NHS Digital) And Primary Care (from member GP practices as data

controllers)

Strictly speaking this is not an outflow from CCG to BCC or practices, but as the CCG commissions

the tool for transfer of the data (i.e.IPA) it is then described as a CCG outflow. As a CCG, there are

DSA's in place between CCG and practices for sanction of flow of PC data for risk stratification

purposes, DARS agreement with NHS Digital that sdactions flow of identifable SUS data for risk

stratification, and DPA with CCG to approve SCWCSU to act as data processor on CCG behalf.

Use separate or manual data extraction mechanisms, manually

develop required analysis and reporting to maintain current

operational level

13/06/2019





Last Updated:

BCCG Contact:

Email:

26.04.19

01494 586771

[email protected]

Telephone:

Who


Where WhenWhat How Additional InformationLegal Basis of Data FlowQS33 Quality and

Safeguarding

CCG Freedom to Speak Up

Guardians

Out-flow CCG staff Staff information associated with

whistleblowing concerns/investigations

Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Less than 5 When required Primary Care Commissioning NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

QS34 Quality and

Safeguarding

Member GP practices In-flow CCG staff Patient records to facilitate reviews

arising as recommendation from

Mazars report (Independent review of

deaths of people with a Learning

Disability or Mental Health problem in

contact with Southern Health NHS

Foundation

Trust April 2011 to March 2015)

Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Less than 5 When required Primary Care Commissioning NHSmail to NHSmail NHSmail [secure] encryption Within UK 0

RC01 Right Care/Planned

Care

CCG member GP practices In-flow CCG Right Care Team/Head of

Planned Care and occasionally

named GP for portfolio

Patient name, DOB and NHS number

with description of symptoms and

pathway experience. Usually relates to

complaint or concern that GP has

raised. Not saved. Usually attachment.

Personal data None - Identifiable Electronic Usually related to a pathway issue - liaise with relevant provider to escalate - they always ask for NHS

number. Practices still vary in utilisation of clinical concerns process which has appropriate IG

safeguards in place (QS24-25)

NHSMail None Information is removed; there may

be a need to send to PALS for

hold archive, after which

delegated from NHS Mail at CCG

end.

Less than 5 When required Pathway troubleshooting NHSmail to NHSmail NHSmail [secure] encryption Within UK


Care

CCG Right Care Team/Head

of Planned Care

Out-flow SCWCSU patient advice and

liaison service/complaints team

Patient name, DOB and NHS number

with description of symptoms and

pathway experience. Usually relates to

complaint or concern that GP has

raised. Not saved. Usually attachment.

Personal data None - Identifiable Electronic Usually related to a pathway issue - liaise with relevant provider to escalate - they always ask for NHS

number. Practices still vary in utilisation of clinical concerns process which has appropriate IG

safeguards in place (QS24-25)

NHSMail None Information is removed; there may

be a need to send to PALS for

hold archive, after which

delegated from NHS Mail at CCG

end.

Less than 5 When required Pathway troubleshooting NHSmail to NHSmail NHSmail [secure] encryption Within UK


Care


NHS Trust

In-flow CCG Right Care Team/Head of

Planned Care and Associate

Director of Contracts

APMG papers: speciality performance

reporting RTT and cancer - initials

only. No corresponding out flow

Personal data None - Identifiable Electronic PAS number removed when asked for it to be taken out. NHSMail None Forwarded to clinical lead for

oversight of performance data.

Contains information for

performance reporting and

historically saved on shared

server G drive for archive should

there be future challenge as to

whether the CCG was aware of

issues the data raises

101 to 1000 Monthly Contract and performance

monitoring - meetings to

discuss the reporting are

arranged by the Trust to which

the CCG is invited

NHSmail to NHSmail NHSmail [secure] encryption Within UK None - Buckinghamshire Healthcare NHS Trust

is the data controller

None - Buckinghamshire Healthcare NHS Trust

is the data controller

MM01 Medicines Management CCG member GP practices In-flow CCG Medicines Management

Team

Blacklisted drugs; asking for

prescription exceptions and non-

formulary items

Personal data None - Identifiable Electronic All requests now being sent direct to the IFR team in SCWCSU by member practices; CCG

medicines management may be asked to confirm funding through cross check to Buckinghamshire

Formulary for individual IFR applications

NHSMail None 0 to 4 When required Management of funding

applications for formulary

drugs



Team

Blacklisted drugs; asking for

prescription exceptions and non-

formulary items

Personal data None - Identifiable Electronic All requests now being sent direct to the IFR team in SCWCSU by member practices; CCG

medicines management may be asked to confirm funding through cross check to Buckinghamshire

Formulary for individual IFR applications

NHSMail None 0 to 4 When required Management of funding

applications for formulary

drugs


MM03 Medicines Management Out of area providers In-flow CCG Medicines Management

Team - medicines optimisation

pharmacists and pharmacists

working in practices

Blueteq system; high cost drugs data

and patients prescribed these high

cost drugs

Personal data Pseudonymised Electronic May include letters from practices/consultants regarding individual patient Medicines Management -

to request prescribing advice for particular patients or request specific drug


drive/system

6 to 20 Daily Medicines optimisation Within software solution Not applicable - must add comment Within system only Within UK 4 2 8 Paper approval if system was unavailable


Care Homes Team

Medicines management information

from GPs; GP hardcopy patient

records

Special

Categories of

personal data

None - Identifiable Hard copy Medical histories, clinical conditions, blood tests Secure filing cabinet/room None 21 to 100 Daily Optimisation of medicines

management in care homes -

making sure Approproate time

and dose to ensure healthy

patients

Manually transferred Not applicable - must add comment Data is transcribed from original record on to a template.

Transported securely and stored in chiltern ccg or gp

practice with limited access. Secure transfer of personal

information procedures

Within UK 4 4 16 If this could be securely stored at care home, there would not

be a need for the CCG to take the data

MM05 Medicines Management CCG Medicines

Management Care Homes

Team

Out-flow CCG member GP practices Medicines management information

from GPs; GP hardcopy patient

records

Special

Categories of

personal data

None - Identifiable Hard copy Medical histories, clinical conditions, blood tests Secure filing cabinet/room None 21 to 100 Daily Optimisation of medicines




patients








(all teams)

Email queries: Prescribed medicines,

new drug therapies

Personal data None - Identifiable Electronic Prescribed medicines, new drug therapies NHSMail Password protected network

drive/system

21 to 100 Daily Optimisation of medicines




patients









Team

Out-flow CCG member GP practices) Email queries: Prescribed medicines,

new drug therapies

Personal data None - Identifiable Electronic Prescribed medicines, new drug therapies NHSMail Password protected network

drive/system





patients







MM08 Medicines Management Buckinghamshire Healthcare

NHS Trust (medicines for

older people division)

In-flow CCG Medicines Management

(all teams)


new drug therapies

Special

Categories of

personal data

None - Identifiable Electronic Prescribed medicines, new drug therapies NHSMail Password protected network

drive/system





patients









Team

Out-flow Buckinghamshire Healthcare

NHS Trust (medicines for older

people division)


new drug therapies

Special

Categories of

personal data


drive/system





patients








NHS Trust geriatricians


Care Homes Team

Outcomes of clinical Multi-Disiplinary

Team medication reviews undertaken

by geriatricians with care homes

pharmacists

Special

Categories of

personal data


drive/system





patients









Team

Out-flow Buckinghamshire Healthcare

NHS Trust geriatricians

Outcomes of clinical Multi-Disiplinary

Team medication reviews undertaken

by geriatricians with care homes

pharmacists

Special

Categories of

personal data


drive/system





patients








Team practice pharmacists,

care homes pharmacists and

dieticians

Through access to EMIS through

username and password or smartcard

access, reviewing patients with

recommendations to GPs for final

decision. Sometimes practices will do

the searches and ask for comments.

Where relevant smart card used to

acccess through pharmacist position

permitted on the system and

authorised by practice as Data

Controller. Two DPIA's and Data

Sharing agreements - one for

pharmacists and one for care homes

team

Special

Categories of

personal data

None - Identifiable Electronic Through access to EMIS through username and password or smartcard access, reviewing patients

with recommendations to GPs for final decision on prescriptions/medication. Sometimes practices will

do the searches and ask for comments. Will include medical history. Where relevant smart card used

to acccess through pharmacist position permitted on the system and authorised by practice as Data

Controller.


drive/system

21 to 100 Daily Through access to EMIS

through username and

password or smartcard access,

reviewing patients with

recommendations to GPs for

final decision on

prescriptions/medication.

Sometimes practices will do the

searches and ask for

comments. Will include medical

history.

Within software solution Password protected Within UK 4 2 8 (d) To protect vital interests


Management Team practice

pharmacists, care homes

pharmacists and dieticians

Out-flow CCG member GP practices Through access to EMIS through

username and password or smartcard

access, reviewing patients with

recommendations to GPs for final

decision. Sometimes practices will do

the searches and ask for comments.

Where relevant smart card used to

acccess through pharmacist position

permitted on the system and

authorised by practice as Data

Controller.

Special

Categories of

personal data



do the searches and ask for comments. Will include medical history. Where relevant smart card used

to acccess through pharmacist position permitted on the system and authorised by practice as Data

Controller.


drive/system






final decision on





history.

Within software solution Password protected This flow may need to be updated to include CareCentric

(a system used in care homes)

Within UK 4 2 8 (d) To protect vital interests

MM14 Medicines Management Care homes across the

county


Team practice pharmacists,

care homes pharmacists and

dieticians

A care home could refer a patient to

the CCG Medicines Management

Team for either medical or dietetic

advice

Special

Categories of

personal data



do the searches and ask for comments. Will include medical history.


drive/system






final decision on





history.

Within software solution Password protected This flow may need to be updated to include Care Centric

(a system used in care homes)

Within UK 4 2 8 (d) To protect vital interests


Management Team practice

pharmacists, care homes

pharmacists and dieticians

Out-flow Care homes across the county A care home could refer a patient to

the CCG Medicines Management

Team for either medical or dietetic

advice

Special

Categories of

personal data



do the searches and ask for comments. Will include medical history.


drive/system






final decision on





history.

Within software solution Password protected Within UK 4 2 8 (d) To protect vital interests


NHS Trust


Team

Insulin pump prior approval requests Personal data None - Identifiable electronic Only NHS Number - through Blueteq Specific software solution Password protected network

drive/system

Less than 5 When required Prior approval so that invoices

can be paid (undertaken by

SCWCSU)

Within software solution Password protected TBC 2 2 4 We would have to ask BHT to undertake this process on our

behalf


Management Team

Out-flow SCWCSU Finance Manager Insulin pump prior approval requests Personal data None - Identifiable electronic Only NHS Number - through Blueteq Specific software solution Password protected network

drive/system

Less than 5 When required Prior approval so that invoices

can be paid (undertaken by

SCWCSU)

Within software solution Password protected TBC 2 2 4 We would have to ask BHT to undertake this process on our

behalf

MM18 Medicines Management SCWCSU IFR Team In-flow CCG Medicines Management

Team

IFR funding requests Personal data None - Identifiable Electronic Software system similar to Blueteq Specific software solution Password protected network

drive/system

0 to 4 Daily Request funding review Post None None N/A 3 3 9


Management Team

Out-flow SCWCSU IFR Team IFR funding requests Personal data None - Identifiable Electronic Software system similar to Blueteq Specific software solution Password protected network

drive/system

0 to 4 Daily Info for panel member email within NHS NHSmail None N/A 3 3 9

MM20 Medicines Management SCWCSU IFR Team In-flow CCG IFR Triage and Case

Review Panels

IFR funding requests Personal data None - Identifiable Electronic Software system similar to Blueteq Specific software solution Password protected network

drive/system

Less than 5 When required Request funding review Post None None N/A 3 3 9

MM21 Medicines Management CCG IFR Triage and Case

Review Panels

Out-flow SCWCSU IFR Team IFR funding requests Personal data None - Identifiable Electronic Software system similar to Blueteq Specific software solution Password protected network

drive/system

Less than 5 When required Info for panel member email within NHS NHSmail None N/A 3 3 9

MM22 Medicines Management EPACT2 In-flow CCG Medicines Management

Team

Online application which gives

authorised users access to

prescription data.

Personal data Pseudonymised Electronic CCG filters data according to age and sex in terms of reviewing prescribing trends. Data is otherwise

lniked between practices on EMIS or other clinical systems to Prescription Pricing Authority


drive/system

1001 plus When required Identifying and analysing drug

spend across patient groups

for cost effectiveness

Within software solution Password protected None Within UK 5 2 10

MM23 Medicines Management EPACT2 Out-flow CCG Medicines Management

Team

Online application which gives

authorised users access to

prescription data.


drive/system

1001 plus When required Identifying and analysing drug

spend across patient groups

for cost effectiveness


CORP01 Corporate SCWCSU In-flow CCG - Deputy Chief Officer Freedom of Information Requests Other Anonymous Electronic 20 working day timescale for response NHS shared drive None none 0 to 4 Daily Response to FOI enquiries email within NHS NHSmail None N/A 4 2 8

CORP02 Corporate CCG - Deputy Chief Officer Out-flow SCWCSU Freedom of Information Requests Other Anonymous Electronic 20 working day timescale for response NHS shared drive None none 0 to 4 Daily Pass info back to CSU email within NHS NHSmail None Within UK 4 2 8

CORP03 Corporate SCWCSU In-flow CCG staff Recruitment process incl interview

packs, appointment forms and HR

contracts

Personal data None - Identifiable Hard copy NHS shared drive Restricted Access Folder Role based access, IT service

Desk provide access to individuals

0 to 4 Monthly Draft contract to CCG for

aproval and signature

email within NHS NHSmail None N/A 3 2 6

CORP04 Corporate SCWCSU In-flow CCG staff Recruitment process incl interview


contracts

Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Role based access, IT service


0 to 4 Monthly Draft contract to CCG for

aproval and signature

email within NHS NHSmail None N/A 3 2 6

CORP05 Corporate CCG - all staff Out-flow Potential employee/applicant Recruitment process incl interview


contracts



0 to 4 Monthly Offer a job/communicate with

candidate

Post None None Within UK 3 2 6

CORP06 Corporate CCG - all staff Out-flow Potential employee/applicant Recruitment process incl interview


contracts




candidate


CORP07 Corporate Potential employee/applicant In-flow CCG - all staff Recruitment process incl interview


contracts




candidate


CORP08 Corporate Potential employee/applicant In-flow CCG - all staff Recruitment process incl interview


contracts




candidate


CORP09 Corporate CCG - all staff Out-flow SCWCSU Recruitment process incl interview


contracts

Personal data None - Identifiable Electronic Payroll NHS shared drive Restricted Access Folder Role based access, IT service



candidate


CORP10 Corporate SCWCSU Human

Resources

In-flow CCG staff Electronic Personnel files Personal data None - Identifiable Electronic Restricted on G drive - LP/DH/NL - info added from HR/line managers - e.g. contracts, sick notes

etc.

NHS shared drive Restricted Access Folder Role based access, IT service


Less than 5 When required To update staff folders with

relevant information regarding

there role/employment

NHSmail to NHSmail NHSmail [secure] encryption None Within UK 3 2 6

CORP11 Corporate CCG staff Out-flow SCWCSU Human Resources Electronic Personnel files Personal data None - Identifiable Electronic Restricted on G drive - LP/DH/NL - info added from HR/line managers - e.g. contracts, sick notes

etc.

NHS shared drive Restricted Access Folder Role based access, IT service


Less than 5 When required To update staff folders with



NHSmail to NHSmail NHSmail [secure] encryption None Within UK 3 2 6


Resources

In-flow CCG staff Historic Paper personnel files Personal data None - Identifiable Hard copy Secure filing cabinet/room Area access by key/keypad Key locked away. Less than 5 When required To update staff folders with



Manually transferred Manual transfer by approved

colleagues

None Within UK 3 2 6

CORP13 Corporate CCG staff Out-flow SCWCSU Human Resources Electronic Staff Records (ESR) Personal data None - Identifiable Electronic People logging in to the system log in to their own information Specific software solution Password protected network

drive/system

User reports Less than 5 When required Staff members log in to ESR to

review their own information



Resources

In-flow CCG staff Electronic Staff Records (ESR) Personal data None - Identifiable Electronic Specific software solution Password protected network

drive/system

User reports Less than 5 When required Staff members log in to ESR to

review their own information



Resources

In-flow CCG Director of

Transformation

Consult OD Personal data None - Identifiable Electronic Stat/mandatory training information NHS shared drive Password protected network

drive/system

Less than 5 When required To record staff completition of

training


CORP16 Corporate Users and Carers In-flow CCG staff Users and carers claim forms Personal data None - Identifiable Electronic NHSMail Smartcard and password

protected

Less than 5 When required Payment of claims Non-secure email Not applicable - claimants use their

own email to send.

Within UK 3 2 6

CORP17 Corporate Users and Carers In-flow CCG staff Users and carers claim forms Personal data None - Identifiable Hard copy None Less than 5 When required Payment of claims Royal Mail (first or second

class)

Royal Mail (first or second class) Within UK 3 2 6

CORP18 Corporate CCG staff Out-flow SCWCSU patient transport

team

Users and carers claim forms Personal data None - Identifiable Electronic NHSMail Smartcard and password

protected

Less than 5 When required Payment of claims Non-secure email Not applicable - claimants use their

own email to send.

Within UK 3 2 6

CORP19 Corporate CCG staff Out-flow SCWCSU patient transport

team

Users and carers claim forms Personal data None - Identifiable Hard copy Claim forms are put into confidential waste None Less than 5 When required Payment of claims Royal Mail (first or second

class)

Royal Mail (first or second class) Within UK 3 2 6

CORP20 Corporate HM Courts Service In-flow CCG staff NHS Resolution/claim requests Personal data None - Identifiable Electronic Claim requests where NHS Resolution appointed as case manager and CCG named as a defendant NHS shared drive Restricted Access Folder Less than 5 When required Claim requests where NHS

Resolution appointed as case

manager and CCG named as a

defendant

Royal Mail (first or second

class)

Royal Mail (first or second class) Claim requests where NHS Resolution appointed as case

manager and CCG named as a defendant

Within UK 2 2 4

CORP21 Corporate CCG staff Out-flow NHS Resolution NHS Resolution/claim requests Personal data None - Identifiable Electronic Claim requests where NHS Resolution appointed as case manager and CCG named as a defendant NHS shared drive Restricted Access Folder Less than 5 When required Claim requests where NHS

Resolution appointed as case

manager and CCG named as a

defendant

Within software solution Password protected Claim requests where NHS Resolution appointed as case

manager and CCG named as a defendant

Within UK 2 2 4

CORP22 Corporate CCG staff Out-flow TIAA (Local Counter Fraud

Specialist)

Counter Fraud - investigation evidence

and reports including and following

referrals

Personal data None - Identifiable Electronic Counter Fraud - investigation evidence and reports including and following referrals NHS shared drive None Less than 5 When required Counter Fraud - investigation

evidence and reports including

and following referrals

NHSmail to NHSmail NHSmail [secure] encryption Reports received are password protected Within UK 4 2 6 Telephone backup to prompt investigation where necessary.

Section 24 of the national standard? Equal obligation

(c) Controller has a legal obligation (g) Substantial public interest, (c) Legal Duty None

CORP23 Corporate TIAA (Local Counter Fraud

Specialist)

In-flow CCG staff Counter Fraud - investigation evidence

and reports including and following

referrals

Personal data None - Identifiable Electronic Counter Fraud - investigation evidence and reports including and following referrals NHS shared drive None Less than 5 When required Counter Fraud - investigation

evidence and reports including

and following referrals

NHSmail to NHSmail NHSmail [secure] encryption Reports received are password protected Within UK 4 2 6 Telephone backup to prompt investigation where necessary

CORP24 Corporate SCWCSU In-flow CCG Head of

Governance/Board

Secretary/Data Protection

Officer

Smartcards list/Registration Authority

requests

Personal data None - Identifiable Electronic NHSMail Password protected network

drive/system

CORP25 Corporate CCG Head of

Governance/Board


Officer

Out-flow SCWCSU Smartcards list/Registration Authority

requests

Personal data None - Identifiable Electronic NHSMail Password protected network

drive/system

CORP26 Corporate SCWCSU In-flow CCG Caldicott Guardian Subject Access Requests Personal data None - Identifiable Electronic NHSMail Password protected files Less than 5 When required Confidentiality breaches

reported on Datix

Within software solution Password protected Within UK

CORP27 Corporate CCG Caldicott Guardian Out-flow SCWCSU Subject Access Requests Personal data None - Identifiable Electronic NHSMail Password protected files Less than 5 When required Confidentiality breaches

reported on Datix

Within software solution Password protected Within UK

CORP28 Corporate Acute providers: could be

from anywhere across the

country

In-flow CCG Head of

Governance/Board


Officer

OOH notifications Personal data None - Identifiable Electronic The CCG had previously been sent A&E discharges from out of area providers NHSMail Password protected files Data not stored by CCG - if

received re-directed to primary

care practice having established

where the patient is registered

Less than 5 When required Re-direction of out of area

discharge notifications

Royal Mail (first or second

class)

Not applicable - must add comment Original notifcations sent by post so re-directd with no

additional protection

Within UK

CORP29 Corporate ASE CORPORATE

EYECARE LIMITED

(Company Registration No.

03425183) whose registered

office is at 14 Quarry Farm,

Bodiam, East Sussex TN32

5RA (“the Supplier

In-flow CCG /SCWCSU Personal data None - Identifiable Electronic Secure network None Less than 5 Monthly United Kingdom, Microsoft Azure

North Europe (Dublin), Mircosoft

Azure West Europe (Amsterdam)

CORP30 Corporate CCG /SCWCSU Out-flow ASE CORPORATE EYECARE

LIMITED (Company

Registration No. 03425183)

whose registered office is at 14

Quarry Farm, Bodiam, East

Sussex TN32 5RA (“the

Supplier

Personal data None - Identifiable Electronic Secure network None Less than 5 Monthly United Kingdom, Microsoft Azure

North Europe (Dublin), Mircosoft

Azure West Europe (Amsterdam)

CORP31 Corporate Patients In-flow CCG (through


Council Communications

Team)

Public consultation responses (though

software solution provided by Ivovem)

Personal data None - Identifiable Electronic ICO registration Z8289153 Specific software solution Password protected files 21 to 100 When required Management of consultations Within software solution Password protected

CORP32 Corporate Patients In-flow CCG (through


Council Communications

Team)

Mailchimp Personal data None - Identifiable Electronic Specific software solution Password protected files 21 to 100 When required Management of consultations Within software solution Password protected

VDU assessment referrals for

eyecare

• Eye and eyesight test

• Spectacles for VDU use

Date, Voucher, Patient, Employee

Number, Description, Unit, Quantity

Net VAT Gross

13/06/2019





Last Updated:

BCCG Contact:

Email:

26.04.19

01494 586771

[email protected]

Telephone:

Who


Where WhenWhat How Additional InformationLegal Basis of Data FlowPC01 Primary Care Primary Care Support

England (PCSE)

In-flow CCG Primary Care Team Special Allocations Service requests

for review

Personal data None - Identifiable Electronic NHS shared drive Restricted Access Folder Less than 5 When required Repatriation of patients NHSmail to NHSmail NHSmail [secure] encryption Patients may also be discussed by telephone (without

consent), or need a response when coming to CCG

offices unannounced (implied consent)

Within UK 2 2 4 Legal Basis for processing

For GDPR purposes NHS England’s lawful basis

for processing is Article 6(1)(e) ‘…exercise of

https://www.england.nhs.uk/contact-us/privacy-

notice/how-we-use-your-information/safety-and-

quality/if-you-are-a-patient-assigned-to-the-special-

allocation-scheme/PC02 Primary Care CCG Primary Care Team Out-flow Primary Care Support England

(PCSE)

Special Allocations Service requests

for review - outcomes, plus requests to

allocate as necessary




Within UK 2 2 4 Legal Basis for processing

For GDPR purposes NHS England’s lawful basis

for processing is Article 6(1)(e) ‘…exercise of

official authority…’. For the processing of

special categories (health) data the basis is

Article 9(2)(h) ‘…health or social care…’.

https://www.england.nhs.uk/contact-us/privacy-

notice/how-we-use-your-information/safety-and-

quality/if-you-are-a-patient-assigned-to-the-special-

allocation-scheme/

PC03 Primary Care CCG Primary Care Team Out-flow Special Allocations Service Special Allocations Service requests

for review




Within UK 3 2 6

PC04 Primary Care Special Allocations Service In-flow CCG Primary Care Team Special Allocations Service requests

for review




Within UK 3 2 6

PC05 Primary Care CCG Primary Care team Out-flow CCG Member GP Practices Practice allocations (including, but not

limited to, follow on from Special

Allocations Service reviews)




Within UK 5 3 15 Where patient doesn't have access to primary care they may

be affeacted, however again they will remain on scheme until

allocated

PC06 Primary Care Interpretation Service

providers

In-flow CCG Primary Care Team Interpretation request invoices (By

exception)

Personal data None - Identifiable Electronic Interpretation service provider to CCG Primary Care Team Specific software solution Password protected network

drive/system

Oracle Less than 5 When required Connecting patients to

interpretation services

Within software solution Password protected Within UK 2 2 4

PC07 Primary Care CCG Primary Care Team Out-flow Interpretation Service providers Interpretation requests invoices (by

exception)

Personal data None - Identifiable Electronic Interpretation service provider to CCG Primary Care Team Specific software solution Password protected network

drive/system

Oracle Less than 5 When required Connecting patients to

interpretation services

Within software solution Password protected Within UK 1 1 1

PC08 Primary Care Local Authorities In-flow CCG Primary Care Team Patient details for purpose of planning

resettlement from refugee camps

Personal data None - Identifiable Electronic Bucks Syrian Vulnerable Persons Resettlement scheme; a government scheme we participate in

where we house refugees from Syria mainly. Local Authorities participate; CCG ensures they are

registered with a GP and have access to medical resources depending on their circumstances.

Department of Health selects the practice that will receive the patient. We will be notified in order for

Finance to make the payment. Likely only name and address as identifiers

NHS shared drive Restricted Access Folder Less than 5 When required Planning resettlement from

refugee camps


Patient name, address and reasons for referral / withdrawal to VPS.

We have a contract for the special allocations service with a practice (in Bedfordshire). We are

notified that a practice has removed a patient. We obtain the immediate removal form from the

practice via PCSE. The Special Allocations Service undertake assessment on patient, which we

receive, with recommendation that patient remains on the service or repatriated back into primary c

are. Recipient is Senior Primary Care Managwr, with request to CCG Chair for clinical view. We then

reply to SAS as to whether we agreed with the recommendation. if the patient is to remain on service

process ends. If they have to be repatriated, it is not an issue unless patient needs to be allocated. If

this is necessary, we should obtain notication from NHSE that patient needs to be allocated. We will

then discuss with another practice about registration. We amy also instrcut PCSE to alocate the

patient.

Potentially patients would not have access to primary care

(IMPACT). PCSE also have separate communication with SAS

so if flow were to stop there would be no major impact

Patient remains registered with the SAS until such as time as

registsred with a named practce, so patient will not be affected

in terms of their access to primary care

Please contact the IG team if further rows are required

13/06/2019


https://www.england.nhs.uk/contact-us/privacy-notice/how-we-use-your-information/safety-and-quality/if-you-are-a-patient-assigned-to-the-special-allocation-scheme/








Data Flow Mapping NHS South, Central and West CSU · Data Flow Mapping NHS South, Central and West...

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