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It should be noted that the requirement on the NHS to inform ICO of breaches only applies to the NHS in England. The requirement was placed by the DoH not ICO and as such only applies in England.

 

Nic Drew

DPO

Cardiff and Vale University Local Health Board

 


From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Ronan Durnin
Sent: 13 November 2009 12:59
To: [log in to unmask]
Subject: Re: Info security[Scanned]

 

I have to say that I agree with Simon. I work in a social work agency with the NI NHS (HSC as we call it here!) and the IG  regime here is brutally detailed. Its implementation varies by organisation, be we are audited against DPA, Records Management and ICT in great detail. The audits leave no stone unturned. Given the size of the NHS nationally, it will more breaches than any other organisation; it should be noted that the NHS employs around 1.3 million staff.

 

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Simon Howarth
Sent: 11 November 2009 17:47
To: [log in to unmask]
Subject: Re: [data-protection] Info security[Scanned]

 

The NHS may be the worst offenders in terms of reporting, but I doubt they are the worst overall.

 

I had this conversation with the Deputy ICO. The NHS have “Information Governance” in place to a very detailed level and well in advance of other public bodies. Part of these arrangements are breach processes that mean that the ICO has to be informed everytime there is a “SUI” Serious Untoward Incident. I work within NHS Trusts and have worked for other public sectors and very few do this apart from the NHS. This means that the NHS is being tarred with a brush for being honest and upfront. Yes, it has to improve in a number of areas, but I wonder, given the literally millions of records movements every day, just what proportion breaches comprise. I would put cash money on any other public authority being worse, but just not reporting there transgressions.

 

Seems the NHS is the whipping boy for being advanced in IG thinking, processes and it’s desire to be open, honest and above board.

 

If the ICO wants to have a downer on the NHS it should concentrate its efforts on some of the overpriced and worrying systems that it is developing which are creating HUGE databases that have a laudable aim, but are being implemented in a questionable way and which may cause far more breaches in the future.

 

The NHS is not perfect, but I’d rather trust my details to these guys than most private sector buffoons (technical word)...

 

Simon Howarth.

 

 


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