It is easy. That is a problem. But if you read each statement very carefully
it allows a degree of flexibility in interpretation which helps a little,
but is far from ideal.
Simon Howarth
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Jones Sandre
(NOTTINGHAM CITYCARE PARTNERSHIP)
Sent: 29 November 2013 14:12
To: [log in to unmask]
Subject: Re: [data-protection] NHS notification of breaches
SIRI: Serious Incident Requiring Investigation.
The first report has been published by the Health & Social Care Information
Centre:
https://www.igt.hscic.gov.uk/Publications/2013-Q3_Report%20of%20H&SC%20Close
d%20Level%202%20IG%20Serious%20Incidents_June%20to%20Sept.pdf
As anyone who has looked at the checklist has probably quickly identified,
it's rather 'easy' to get to a total score of 2 without there actually
having been any damage or distress caused ...
Sandre
Sandre Jones
Information Governance Lead
Nottingham CityCare Partnership
1 Standard Court
Park Row
Nottingham
NG1 6GN
Tel: 0115 883 9534 EXT 39534
Mob: 07545 422312
Nottingham CityCare Partnership CIC is registered as a company limited by
guarantee.
Company Registration Number: 07548602
Registered address: 1 Standard Court, Park Row, Nottingham, NG1 6GN
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of White Sarah (DEVON
DOCTORS LTD - NQW)
Sent: 29 November 2013 13:42
To: [log in to unmask]
Subject: Re: [data-protection] NHS notification of breaches
---
This message was sent from an email address external to NHSmail but gives
the appearance of being from an NHSmail (@nhs.net) address. The recipient
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The identified sender is [log in to unmask]
---
Yes it is. The trouble is the IG SIRI is a L2 and you report on the toolkit,
the ICO are informed automatically whether you would have or not. The SIRI
grading criteria doesn't quite seem to mirror, or say "see the DPA" their
grading criteria is rather different.
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Baines, Jonathan
Sent: 29 November 2013 13:35
To: [log in to unmask]
Subject: Re: [data-protection] NHS notification of breaches
I think this is the key document, but NHS colleagues can no doubt clarify
https://www.igt.hscic.gov.uk/KnowledgeBaseNew/HSCIC%20IG%20SIRI%20%20Checkli
st%20Guidance%20V2%200%201st%20June%202013.pdf
Jonathan Baines
Complaints and Information Rights Officer Legal and Democratic Services
Buckinghamshire County Council
01296 383681
Follow us on twitter @buckscclegal
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of GRAHAM Susan
Sent: 29 November 2013 13:21
To: [log in to unmask]
Subject: [data-protection] NHS notification of breaches
I have heard it said that it is standard practice for the NHS to notify all
data protection breaches to the Information Commissioner, and that this is
why so many of the monetary penalty notices relate to NHS organisations. Is
there a policy document that sets out the NHS approach to breach
notification and defines what should/should not be notified?
Best wishes
Susan Graham
--
The University of Edinburgh is a charitable body, registered in Scotland,
with registration number SC005336.
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