Manchester Primary Care Trust

By Joseph Ramirez,2014-04-11 06:25
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The PCT was able to confirm it's compliance with these requirements prior basis and is chaired by the Assistant Director Corporate Governance and Risk.

    Information Governance Annual Report


1 This brief report summarises the results of the Information Governance Toolkit

    submission presented by the PCT in March this year and in addition the other main

    IG developments which have occurred in the past year.


2 Connecting for Health (CfH) helpfully sets out the objective of Information


     “Information governance allows organisations and individuals to ensure that personal

    information is handled legally, securely, efficiently and effectively, in order to deliver

    the best possible care. It also enables organisations to put in place procedures and

    processes for their corporate information that support the efficient location and

    retrieval of corporate records where and when needed, in particular to meet requests

    for information and to assist compliance with corporate governance standards”.

3 Information Governance provides a framework to bring together all of the

    requirements, standards and best practice that apply to the handling of information.

IG Toolkit

4 Attached is a summary of the outcome of the IG Toolkit submission made in March

    2008. Completion of the Toolkit is mandatory on all NHS organisations. The result

    was 63% which once more gave the PCT an amber status score. This represented a

    12% increase on the PCT’s score for 2006/07 and can be considered a good

    performance given the impact of the reorganisation of the three PCT’s during the first

    half of 2007 and the short-term resource issues which resulted. Once more there

    was quite considerable variance in performance across the six areas of the Toolkit.

    The PCT scored over 70% in the both the Information Governance Management and

    Secondary Uses Assurance sections which represents a green status. However the

    Corporate Records Assurance section score which remains at red status continues to

    be a cause for some concern.

5 Overall the PCT’s performance this year is indicative of the general trend amongst

    other Greater Manchester PCTs and the percentage increase achieved this year

    should almost certainly allow for a further increase to over 70% and a green status for


Statement of Compliance

6 In addition to the completion of the IG Toolkit the PCT was also obliged to meet all of

    the requirements of the Statement of Compliance in order to maintain the connection


    to the N3 Network and/or NHS CfH digital services. The PCT was able to confirm it’s

    compliance with these requirements prior to the deadline and Connecting for Health

    have confirmed that the Trust can maintain the N3 connection.

Data flows

7 Following the high profile loss of personally identifiable data by a number of Public

    Sector organisations, NHS Chief Executive; David Nicolson wrote to all Trusts

    requiring that each carry out a data mapping exercise of all the flows of personally

    identifiable information in and out of their organisations. In addition he asked each stTrust to provide assurance to SHA’s by 31 March 08 that all such flows were secure

    and risks had been mitigated. Manchester PCT conducted a full audit of data flows

    with the co-operation of each Directorate and assurance was provided to the SHA by

    the deadline. However as the Board previously felt some transfers of patient data

    were essential for patient care and could not be halted before the risks could be fully

    mitigated these transfers continue in the short term with the Board’s approval. An

    encryption tool will provide the long term solution to these outstanding issues and it is

    hoped this will also ensure personally identifiable information can be transferred more

    efficiently while simultaneously ensuring security is maintained. The PCT is currently

    responding to the national procurement of the McAfee Safeboot encryption tool made

    by Connecting for Health. The PCT is now in the final stages of purchasing the

    licences for this product and should be in a position to begin the roll out of the tool in

    early May with those services at higher risk forming a high priority group for early


IG Sub Group

8 IG is co-ordinated by the IG sub-group which meets on a bi-monthly basis and is

    chaired by the Assistant Director Corporate Governance and Risk. Membership

    includes the Trust’s Caldicott Guardian, the Operational Risk Manager, the Head of

    Clinical Governance for MCH and the Associate Directors of IT Infrastructure and

    IM&T Programmes. The group continues to explore a number of operational issues

    including the discussion of incidents involving IG. The Sub-Group has also recently

    approved the PCT Confidentiality Policy and has agreed to continue to be the forum

    for discussion and approval for IG of policies and procedures.

IG Support Capacity

9 Whilst IG is everyone’s responsibility, specialist expertise is available to the PCT. The

    Caldicott Guardian role remains in the Medical Directorate. In the new PCT structure

    there are two full-time IG posts. Currently the post of IG Manager is vacant. The

    Corporate Services Manager continues to have responsibility for corporate records

    management and Freedom of Information requests. Clearly the IG Manager vacancy

    has had some affect on the overall resources available to support staff but this should

    be resolved in the near future.

Action Planning

10 The amber result in this year’s IG Toolkit clearly provides the PCT with the target of

    increasing this to above 70% and a green result next year. There are a number of

    areas requiring action particularly centring on those requirements where the score

    has not increased above a level 1; these requirements are mostly found within the

    Data Protection and Confidentiality and Corporate Records Management sections.

    Therefore increasing the scores in these areas will be a particular priority in the


    coming year and this should be a very achievable target which will ultimately lead to a

    fairly significant uplift in the PCT’s overall Toolkit status.

11 The purchase of the IG module of the Performance Accelerator should also provide

    for a more co-ordinated approach to the completion of the IG Toolkit.


12 The PCT has a number of challenges and risks around IG areas as set out in the

    Corporate Affairs Risk Register. The recent work completed on data flow mapping

    and the advances made in IG Toolkit performance provide very real opportunities for

    a continued improvement in PCT performance in this in increasingly high profile area.

Alex Daybank

Information Governance Officer


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