Posted on behalf of Jenny Grodzicka
Social Care Record Guarantee http://www.nigb.nhs.uk/social
Dear RMS Members ,
I am interested in your views on this document (see above link). We have
spotted some areas where the wording causes us concerns and would
appreciate learning about your approach to them. It is mainly that there are
some broad statements that could have quite an impact on our work, as such
things are not usually so cut and dry.
1. A general feeling that the document is telling the public that they
have complete control over their information, whereas sometimes we may be
legally bound to use/share information to provide a service, e.g. inspections
and also with contractors (a private care home may be providing a service on
behalf of the authority and therefore needs the information, there is a
difference legally but the public don’t always see this and view it as sharing).
It is mentioned on page 8, but I’m not sure the message is strong enough.
2. Page 6 – there are not only 2 exemptions under the DPA, e.g. legal
professional privilege. This paragraph reads as if the two listed are the only
reasons that information would be withheld.
3. Page 12 (paragraph 11). What are your views on this? Would you
have a list of people or organisations? Is it possible to produce such a list?
Concerns about the logistics of informing people if someone needs to look at
their information, in some cases this may not happen, e.g. police investigations.
4. Page 14 – separate records. Our historic files are often in the form
of ‘family files’. We are a bit concerned that the public may expect this of all
files, current or historic.
5. Page 15 – parents - asking parent for permission before show it the
child. It is not always necessary to seek permission (e.g. information already
known to the data subject) and sometime even if without permission
information may need to be disclosed.
6. Plans for the future – using the term ‘hide’ is not felt to be the best
word to use here.
Any thoughts on how you will deal with these or other issues you foresee
would be much appreciated.
Many thanks
Jenny Grodzicka
Corporate Information and Compliance Manager
Community and Adult Care Directorate
Gloucestershire County Council
Shire Hall
Westgate Street
Gloucester
GL1 2TG
Tel: 01452 426186
Email: [log in to unmask]
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