Can We Use Video Conferencing For Staff Communications or For Consultations with Patients?
NHS X encourages the use of videoconferencing to carry out consultations with patients and service users.
They have deemed it appropriate to use video conferencing tools such as Skype, WhatsApp, Facetime as well as commercial products designed specifically for this purpose.
However, we would recommend considering one of the many locally developed offerings that can link directly in with software, are often UK based etc. Please see a list of approved software solutions in our log.
Should We Engage with our DPO Before Using These Tools?
In light of the current crisis and the need to move quickly, the Information Commissioner has confirmed a pragmatic approach to governance during this time. The consensus is that a 'lighter' assessment can be completed with retrospective assurances provided at a later date.
You should let your DPO know what you are doing though, this allows us to maintain a log and to support you in the event of any breaches or complaints from members of the public. It will also allow us to advise you of any particular measures that should be in place for the software you have selected.
Should We Be Obtaining Written Consent or Providing Any Particular Privacy Notice for Use of this Software?
The consent of the patient or service user is implied by them accepting the invite and entering the consultation. But you should safeguard personal/confidential patient information in the same way you would with any other consultation; by making sure you are in a private space, by validating the identity of the patient verbally at the outset of the consultation.
You are not in a position to provide full privacy materials prior to the use of video consultations but as your DPO, we will look to add some materials to your website to support.
What If I Am Using My Own Phone or Computer?
If you are working from home and using your own internet you should check that your internet access is secure (e.g. use a Virtual Private Network and/or if possible avoid public wi-fi) and that any security features are in use.
If you are taking any physical documents home with you that contain personal/confidential patient information, you should also ensure the security of these documents at your home and when travelling.
You should take reasonable steps to ensure your own device is safe too; setting a strong password; using secure channels to communicate e.g. tools/apps that use encryption; and not storing personal/confidential patient information on the device unless absolutely necessary and appropriate security is in place.
What If I Need to Share Information With My Colleagues Or Other Bodies After a Consultation?
It is essential that during the Covid-19 outbreak health and social care professionals are able to talk to each other. You will need to share appropriate information about the people in your care including with social care, where possible using secure mail, NHSmail and MS Teams. Where these tools aren’t available you should use this guidance to suggest ways that you can speak to your colleagues.
What Software Has Been Approved?
Please find a link to our log which shows which software / providers have been approved and includes a copy of the light impact assessment. This will be re-uploaded each day.