Fair processing – guiding principles
The guiding principles we follow for fair processing of information.
The six principles
ABL Health is guided by the six principles of good practice for information sharing which were identified by the Caldicott Report, 1997. Those principles, and how ABL Health will apply them with regards to information sharing, are listed below.
ABL Health's Caldicott Guardian will clearly define the purpose of disclosing any service user information before any information sharing protocols are authorised. For example, if information is not shared then a service user may receive the wrong care.
ABL Health has systems in place to ensure that service user information is only used when absolutely necessary, and not for administrative ease. For example, all service users receive a code which is only available on a secure database, which is then used when staff discuss a service user's care to ensure high levels of confidentiality.
ABL Health will scrutinise all service user information to ensure each individual item of information is justified.
Only individuals directly involved with a service user's care need to have access to their personally identifiable information. For example, only employees who are identified as a 'care giver' to a service user will have access to their notes through a secure database.
ABL Health takes regular action to ensure that those handling personally identifiable information are aware of their responsibilities and obligations to respect patient/client confidentiality through a thorough training process.
All employees receive information governance training as part of their induction and are required to participate in annual corporate training and assessments.
ABL Health's Information Governance policies clearly state what is legal and how to comply with best practice. All employees are expected to ensure they are consistently within these boundaries.
The Caldicott Guardian is responsible for ensuring that every use of patient identifiable information is lawful.
Deciding whether to share or withhold patient information
Any information sharing must be absolutely necessary and authorised. It must be relevant and not excessive.
ABL Health will always be led by the Information Governance Lead, the SIRO and the Caldicott Guardian where information sharing agreements are to be put in place. All information sharing protocols must take into account and follow the legal and guiding principles discussed above.
The decision to enter into an information sharing agreement will never be taken without authorisation from the Director Board.
Who may require information to be shared?
Anyone requesting information must be able to show that their justification for using, holding, processing, retaining or destroying the data is in line with the legal and guiding principles identified above.
Health care for service users may be provided by a range of specialists within ABL Health, for example psychotherapists and physical activity experts. Where relevant, information may be shared to ensure a continuity of care and to ensure that all service user needs are met.
In some instances health care can be a shared responsibility between providers. For example, an organisation may be a referral agent into a service for ABL Health, and may request an update on client progress. ABL Health will perform an internal check to ensure that the sharing of all information is in line with legal and guiding principles, and may share necessary information to increase the quality of care delivered.
Some regulatory bodies require notification of specific instances, for example the death of a service user. This information would always be anonymised or pseudonymised but would be provided where necessary.
All enquiries from the Coroner's office would be dealt with by the Information Governance Lead and the Caldicott Guardian, and would be in line with ABL Health's patient record and Information Governance policies.
As stated above, the Information Governance team will always handle these cases. ABL Health employees receive annual training on when to disclose or withhold information from such organisations. In some instances an individual's right to confidentiality may be overridden by the public's interest in having access to information. More information on this can be found in ABL Health's Freedom of Information policy.
Under no circumstances should ABL Health employees communicate directly with the media. All enquiries will be dealt with by ABL Health's communications and marketing manager. Service users will always be asked to give consent prior to a media release which may be used to publicise a service run by ABL Health.
Where ABL Health receives or makes a request to share information, the Information Governance Team (Information Governance Lead, SIRO and Caldicott Guardian) will make an informed decision on a case by case basis. This decision will be centred around whether there is a statutory duty or court order to share.