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The Information Strategy and DPA. Dawn Monaghan Group Manager Information Commissioners Office. The Information Strategy. ICO Views Welcome general aims Keen to ensure that the ‘human’ elements are considered as well the technical Encouraged re Data being an ‘individuals’ data
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The Information Strategy and DPA Dawn Monaghan Group Manager Information Commissioners Office
The Information Strategy • ICO Views • Welcome general aims • Keen to ensure that the ‘human’ elements are considered as well the technical • Encouraged re Data being an ‘individuals’ data • Integrated (shared) data a good thing • Positive about the drive to a culture of transparency
Key Initiatives and ICO involvement • Information Governance Review Panel • Code of Practice on confidentially • Confidential Advisory Group • National Information Advisory Group • Regular Stakeholder meetings and contact with other interested parties
Specific Work HSCA 2012 and its interfaces with the DPA New data flows and clarification of Data Controllers’ in the new structures Internal Policies within the ICO Care.data - GPES On Line Access to Records
HSCA 2012 interfaces with the DPA HSCA 2012 s254 NHSE may ‘direct’ HSCIC to ‘establish and operate a system for the collection ….’ HSCA 2012 s255 Any person may ‘request’ that the IC to ‘establish and operate a system ….’ HSCA 2012 s258 Before establishing a system the ‘IC must consult’ HSCA 2012 s259 The Information Centre may ‘require and request provision of information’
New data flows/clarification of Data Controllers Care Providers Collection of data sets by HSCIC HSCIC to CCG’s, LAPH, NHSE CSU’s /Area Teams/DMIC’s/ LAPH Data Controller relationships?
Internal Policies within the ICO Notification DPA Complaints/ FOIA s50 cases Enforcement investigations Tribunal cases Enquiries
Care.data - GPES NHSE/HSCIC/Care Providers Data Controller responsibilities s259 the ‘power to require’ Engagement of s35 of DPA s27 (3) (4) DPA ‘..to the extent to which they are inconsistent with the disclosure in question…’
On Line Access to Records Pilot schemes - to date considered and compliant Welcome the Roadmap from RCGP’s Like more involvement as it goes forward May improve accuracy
On Line Access to Records Opinions and 3rd party data Subject Access Requests Enforced Subject Access Technical and organisational measures
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