Last September I posted a blog which shared the recommendations of the Information Commissioners Office (ICO) on the use of NHS numbers. The guidance from the ICO and Information Governance Alliance has since been updated and clarified in respect of the Health and Social Care Act and I thought it would be useful to share this.
New duties to share and to use the NHS number
Two new duties came into force in October 2015 as part of the Health and Social Care (Safety and Quality) Act. These are:
- A requirement for health and adult social care organisations to use a consistent identifier (the NHS number) for sharing data for the direct care of a patient.
- A legal duty requiring health and adult social care bodies to share information with each other for the direct care of a patient.
The Health and Social Care Information Centre explains the implications of the Act and provide guidance to aid local authorities in deciding if their use of the NHS number is appropriate. You can view this on their website.
Guidance on the use of the NHS number
In particular, there is a useful document clarifying the rules on the use of the NHS number by local authorities and adult social care providers.
The Exclusions section on page 1 is particularly pertinent:
Local Authorities are not able to use the NHS Number as the unique identifier for all their personal records, but there is no restriction on Local Authorities and those organisations working in the care contexts identified in the following section being able to hold and use the NHS number for care purposes providing that Data Protection requirements are met. Whilst there is no legal restriction on wider use of the NHS Number, Government policy requires that the NHS number must not be used outside of the care context nor as a more general identifier e.g. for Local Authority internal purposes such as housing or education for clients unless there are relevant health or care considerations. (guidance copied from the Health and Social Care Information Centre website)
Applying this to your data in One
Based on the exclusions guidance above, I do NOT recommend that local authorities use the facility to import the NHS number against all children. The ability to import should, however, provide a more efficient method to enter this data for children where a clear medical/care need has been identified.
It should also be noted that this data must be removed once that care/ medical need has been met and is no longer applicable.
Please consider the information provided by the ICO and IGA carefully before using this facility to bulk import student details.
For further information please visit the Health and Social Care Information Centre website