Towards protecting data in secondary uses

Last summer, the Department of Health consulted on a programme called “Accredited Safe Havens” (ASH), an idea by which individual level medical records could be transferred somewhere (an ASH) for certain reasons.

While research needs clear individual level data for some applications (because while researchers research a topic, they don’t know the precise question – if they did, it wouldn’t be research), for the two other main uses, risk stratification, and invoice reconciliation, there are alternate approaches available which don’t need to transfer millions of individual level records.

In our response to the DH consultation, we summarised those approaches rather briefly, with various grey areas.

Updated 2018: The various discussion documents are now available directly:

  1. An introduction to the approach
  2. Risk Stratification
  3. Invoice Reconciliation (2018)
  4. Invoice Reconciliation (2015)
  5. Invoice Reconciliation for A&E (September 2015)

If DH/NHS England were to put any resources into this, there may be no individual level records that need to be transferred under provisional, interim governance, blanket authorisations that have been renewed “temporarily” since 2013.

We’re also giving evidence to the Health Select Committee tomorrow, and put one new idea into our submission as an annex: “CLASSIFIED when completed”: Which needs better protection – official memos, police witness statements, or all our medical records?

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