Hi everyone
I'm hoping someone with an understanding of the NHS Records Management Code of Practice might be able to help me out with interpreting an aspect of it, please? I’m reviewing a DPIA about a new optometry clinic that is being established at my university, including an electronic patient management system. This system does not seem to have the ability to delete patient records at any point, but can ‘archive’ them so that access is restricted or ‘anonymise’ them so that statistical data etc is still there but everything identifiable is gone. I note that the NHS RM Code of Practice states:
“Where the [electronic] system has the capacity to destroy records in line with the retention schedule, and where a metadata stub can remain, demonstrating the destruction, then the Code should be followed in the same way for digital as well as paper records with a log kept of destruction. If the EPR does not have this capacity, then once records reach the end of their retention period, they should be made inaccessible to system users upon decommissioning. The system, along with the audit trails, should be retained for the retention period of the last entry related to the schedule.”
If we say that ‘anonymisation’ is the same as ‘destruction’, what is an appropriate “metadata stub”? Would that require some kind of identifiable information so that we can prove we once had that person’s record but deleted it on a certain date (so retaining eg name+dob or NHS number)? If we anonymise the records, will it be impossible to retain an appropriate metadata stub, or does it just mean keeping evidence that a batch of unidentifiable records were destroyed/anonymised? Should we therefore only be ‘archiving’ the records, keeping the personal data for as long as we keep the system but restricting access to those that have passed the end of their retention period?
(The system is i-clarity, if anyone has any specific experience of that system.)
Thank you
Sian
University Records Manager
University of Huddersfield
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