This week Kafico contributed to the NHSX consultation on Guidance for Information Sharing.
NHSX aims to create the most advanced health and care service in the world using experts in technology, digital, data and cyber security to deliver on the Health Secretary’s tech vision and the Long Term Plan for the NHS.
We highlighted the need for more clarity when sharing information for purposes beyond care, despite data protection law clearly incorporating healthcare planning as part of the primary purpose of healthcare, there is still a lack of confidence around using data for these purposes - minimisation not withstanding.
We also recommended that more information should be provided around Integrated Care Records - we feel in particular that there should be more information about how to establish, document and manage the joint and several liabilities associated with joint controllership.
Finally, we asked for more guidance around anonymisation controls, we would like to see the threshold provided in data protection law made clear in practical guidance for health and social care professionals.
NHSX has lofty goals and we believe that clear guidance is critical for Controllers to have the confidence to engage with the wider digital economy.