Risking the wrath of the list owner, I question Alison's assertion, "I don’t
think Allan’s example is very relevant to the issue of ‘safe havens’ for
commissioning."
The point is universal: don't expect IT systems to be secure, whatever the
restrictions and penalties. The weak point is the staff. If Alison wants a
domestic example, today's paper reports a PCSO ("assistant" policewoman) who got
into the "secure" area at Gatwick airport and confiscated cash from passengers
at the departure gates - claiming they were not allowed to take more than £1000
in cash out of the country.
In respect of the report and commenting, on first reading I find it garbled and
hard to respond to: it conflates the storage and use of medical data for patient
treatment (para 1, 5, 36) with the use for management and audit (para 3, 37,
38), use for medical-related research and use for wider social research (paras
10, 11, 12, 54). An example of woolly thinking (or language) is in para 14:
"Examples of the benefits of data sharing include to: ... identify who could be
at risk of a condition or would benefit from a particular treatment". Does this
refer to identifying individuals for personal intervention or classes of people
for health campaigns? Probably both.
It's not long since the last NHS grand IT initiative crashed and was abandonned
at great cost. The timescale suggested in para 6 is unrealistic, and if these
regulations "apply in relation to England only" (para 13), where does that
leave, eg, Welsh patients whether treated in Wales or England?
Alison is performing a public service in publicising this type of
"consultation", which one suspects is intended only for the parties already
engaged in the process.
As a parting shot, another example of woolly langauge, reflecting either woolly
thinking or the poor standards of teaching language and logic: "Should there be
any restrictions as to the type of body which might become (in whole or in part)
an ASH, for example, a social enterprise, a private sector body or a commercial
provider (working under a data processor contract)?"
Allan
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