Update 19/3/17: We understand TPP is due to provide more information on their transparency process. We will update this notice when we have read what TPP provide.
There is a problem with the security of GP records held on TPP SystmOne, where your records are protected only by a Code of Conduct:
If you do not receive care from an organisation that uses TPP SystmOne, this issue does not affect you. You can check whether your GP practice does use TPP SystmOne by putting your postcode into this online form; select your GP practice from the list provided, and you should end up on a page which asks you for a username and/or password. If this page has anything other than a SystmOne/SystmOnline logo at the top of the page in big blue letters, then this issue doesn’t affect you. If you see a TPP SystmOne or SystmOnline logo, then you are affected.
(The logo looks like this, but in much bigger letters: )
Nothing below affects you, unless your doctor uses TPP SystmOne.
Due to a failure by TPP SystmOne, your record may be visible to authorised users in other parts of the NHS that also use TPP SystmOne, unless you (or your GP) have previously taken an active decision to prevent this.
You will know if you took this decision already, because such a decision will affect the care you can receive as it affects who can access your GP record, including for services such as out-of-hours care. While access should be able to be restricted by your GP practice to only those who provide them out-of-hours care, that restriction is not currently offered by TPP. Therefore any authorised user, at any organisation that uses TPP SystmOne, can potentially access at least some of your record.
If you have major urgent concerns about this, and if you only receive care from a single NHS organisation – e.g. your GP, or a single mental health organisation, or a single pharmacy, etc. – you can simply turn off what is called “sharing out” by that organisation using this form BUT please ensure you read the information on the form itself, and the next paragraph, before making that decision.
For many people, turning off “sharing out” is an option that may affect your care, even in the medium term, while TPP fixes the problem.
In the interim: if you are concerned, and turning the “sharing out” feature off would impact your care – which is likely for many people – you can write to your GP practice manager and ask them to (in TPP’s words) “use the Record Sharing node within the patient record to view which other organisations are sharing in the patient’s record and can therefore access the information you have shared out”. In other words, you can ask the practice manager to provide you with a copy of the full list of organisations and the dates on which each one accessed your details for the last 6 months – or around specific dates, if you have a specific concerns.
If there are accesses from institutions you do not recognise, medConfidential will publish more information on this post in the next few days about what happens in those rare cases. In most cases, if the dates of access are around a day in which you were at a different NHS provider nearby, it is highly likely that information will have been shared between your care providers. (We will expand on this shortly.)
TPP are actively working to fix this issue, implementing a change that will let you use your login to your GP’s website so that, in future, you will be able to see the ‘audit trail’ of uses that your GP practice manager can see now. If you don’t already have a login to your GP website, it would probably be helpful to get one in advance – as it will have other features beneficial to you.
We understand that TPP are also taking a number of other steps we’ve not covered here
Longer term outcomes
As medConfidential said when commenting on this issue, “Failures of this sort are exactly why patients must be able to see by which organisations their GP records have been accessed.” We have said this before, when organisations have similarly failed.
We strongly welcome that “TPP will be making amendments to the record audit within SystmOnline, this will show the patient every organisation that has accessed the information you[r doctor] record within their electronic record.” (See the bottom of page 2 of this TPP document.) This work will help reduce the harm of data breaches across the NHS, and not just for TPP.
Such failures have happened before, and will happen again, and again, until – as Dame Fiona Caldicott recommended last summer – Jeremy Hunt commits to ensuring that every patient in the NHS can see how their data has been used.
TPP has now committed to telling patients how their data is used… what about everyone else?
For NHS staff
For GP practices: Please read page 2 of this TPP document linked from your TPP noticeboard, and ask your GPSoC provider to accelerate their work on delivery of the audit trails to patients, and a resolution of the underlying problem. If you have queries, contact your local Caldicott Guardian.
For Caldicott Guardians: please see the (imminent) guidance from the Council of Caldicott Guardians and the National Data Guardian.