Wales Information Sharing Design Team

1
Wales Information Sharing Design Team

• Accord on the Sharing
• of Personal Information
• for organisations involved in the safety, health
  social wellbeing of people
• A Practical Approach to Information Sharing

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Wales Accord on theSharing of Personal
Information
From humble beginnings .

• Information Security Wales working group (Welsh
  Office)
• Group stopped
• Likeminded managers met
• Created Wales information governance managers
  network (informal, NHS)
• Sub-group
• Invited others e.g. SSD, Housing, Welsh Assembly,
  Legal Dept., Information Commissioner
• Draft sent for consultation across Wales
• Final document published Jan-Feb 2007
• Wales roadshow March 2007
• Implementation
• 12 month review and some changes
• Now into version 2

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Wales Accord on theSharing of Personal
Information

• WASPI is
• Regular sharing of personal information between
  organisations
• It is a framework and not just one document
• It deals with routine, agreed and regular
  exchanges of personal information
• It facilitates authorised lawful exchanges of
  personal information between signatory parties
• It establishes mechanisms for this exchange
• It is a practical approach to working together
• Not just for Wales
• Not just for health and social care

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Wales Accord on theSharing of Personal
Information

• Why do we need it? (Service Challenges)
• Push to share/disclose information coming from
• Practice/service developments and their Service
  user / patient expectations
• Policy initiatives sharing central to effective
  care and policies in health and social care
• High profile national failures (Climbie, Soham
  etc.)
• Information sharing seen as a major barrier to
• Implementing Integrated Childrens Service in
  England
• Implementing Unified Assessment in Wales
• Mental Health Joint Community Support Team

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Wales Accord on theSharing of Personal
Information

• Why do we need it? (Service Challenges)
• Constraints and barriers (or challenges) coming
  from
• Fragmentation of services (LAs, LSBs, 1000s of
  providers!!) with different organisational
  standards e.g. PCT, Trusts, independent sector
  private, not-for-profit, voluntary
• Professional codes of ethics, professional
  cultures
• Legal complexities and misunderstandings
  particularly of the Data Protection Act
• Government Action
• Confidentiality Code of Practice for Health and
  Social Care in Wales
• ICO Code of Practice
• Non-Statutory Guidance
• Caldicott

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Wales Accord on theSharing of Personal
Information

• Benefits
• For Service User
• Improved care reduce delay, focus
• Improved trust and education (about what we do)
• For Staff
• Certainty, reduce delay
• Improved knowledge and training
• Effective use of resources
• For Organisation
• Reduces Risk
• To service users
• To staff
• To the organisation

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Wales Accord on theSharing of Personal
Information

• The Framework
• 1 the Accord
• the common set of corporate principles and
  standards under which partner organisations will
  share information
• 2 the PISPs
• operational procedures to be applied to the
  sharing of personal information for specific and
  lawful purposes
• (Website www.wales.nhs.uk/waspi)

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Wales Accord on theSharing of Personal
Information1 The Accord

• The Accord provides
• A SINGLE corporate sign up
• Commitment to meet defined principles and
  standards (not necessarily immediately)
• Commitment to the WASPI framework for sharing
• Commitment to share on a practical common sense
  basis

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Wales Accord on theSharing of Personal
Information

• Accord on the Sharing
• of Personal Information
• for organisations involved in the safety, health
  social wellbeing of people
• A Practical Approach to Information Sharing
• PISP

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Wales Accord on theSharing of Personal
Information2 The PISP

• Whats a PISP?
• The Personal Information Sharing Protocol (PISP)
• Promotes concept of Information Sharing Community
• Can be specific or generic, service-wide
  (flexible)
• Aimed at everyone
• Need people who negotiate and develop its contents

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Wales Accord on theSharing of Personal
Information2 The PISP

• Whats a PISP?
• In 4 Parts (plus appendices)
• Part A
• Describes scope, purpose, functions and
  information sharing community
• Part B
• Sets out the rules and operational procedures
• Part C
• Describes the specific rules for dealing with
  consent and relevant legislative powers allowing
  the collection and disclosure
• Part D
• Describes the details of the information to be
  shared (wwwwwh)

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Wales Accord on theSharing of Personal
Information 2 The PISP

• Developing a PISP
• Know your business-
• Why share what lawful purpose does it serve?
• What high-level functions are being discharged?
• Which staff must follow this PISP?
• Which service users are covered?
• What personal information is being shared?
• Whether working with the private and voluntary
  sectors entails any additional rules
• Know your organisation-
• Whos responsible for developing PISPs and their
  sign off
• Whos responsible for defining the Review
  arrangements
• Who provides advice

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Wales Accord on theSharing of Personal
Information 2 The PISP

• Where do we start? (cont)
• Know your powers and boundaries-
• Where do we get the powers/vires to do what we
  intend to do?
• Does my work have a clear statutory footing?
• Any Regulations issued as Statutory Instruments?
• Does any statutory guidance apply to my work?
• Can I rely on general or administrative powers?
• Know the law of information sharing-
• Do I know enough?
• Discuss with someone who can help e.g. IG or DP
  Manager, Legal Services

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Wales Accord on theSharing of Personal
Information2 The PISP

• The 4 Parts Part A
• Describes scope, purpose, functions and
  information sharing community
• Scope describes the information sharing
  community
• Purpose why the need to share
• Functions what are the functions of the
  information sharing community
• The community list of the organisations who
  will be sharing the information
• Service users description of the people about
  whom the information will be shared
• Value why share if its of no value to the
  individual(s)
• General about training, security, complaints and
  review

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Wales Accord on theSharing of Personal
Information2 The PISP

• The 4 Parts Part B
• Sets out the rules and operational procedures
• Describes at high level what information will be
  shared
• demographics, risk assessments, relationships
  etc.
• Identifies key information to be shared
• Name, age, date of birth, service identifier e.g.
  nhs no. ssd ref.
• Describes information collection tools
• Describe IT system, forms, client files
• Describes when the information will be shared
• Need-to-know basis
• Lists other rules to follow for each organisation
• Information security
• Retention and destruction
• Data quality

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Wales Accord on theSharing of Personal
Information2 The PISP

• The 4 Parts Part C
• Describes the specific rules for dealing with
  consent
• and
• Relevant legislative powers allowing the
  collection and disclosure
• Lists in detail the statutory powers
• not simply the name of the Act but the section
  and its description

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Wales Accord on theSharing of Personal
Information 2 The PISP

• Part C - approaching consent issues
• Crucial to get consent right
• Define what happens under normal circumstances
  for your services
• The type or types of consent that are appropriate
  to the process
• Operational instructions about standard and
  non-standard requirements
• Ensure that consent is informed etc.
• Set out a clear pathway for circumstances when a
  service user cannot give consent
• DONT FORGET POVA, Child Protection and emergency
  services.
• Consult the IG/DP experts at the START of the
  process.

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Wales Accord on theSharing of Personal
Information2 The PISP

• The 4 Parts Part D
• Describes the details of information to be shared
• (a table, spreadsheet etc)
• Kiplings six friends
• who?
• what?
• when?
• where?
• why?
• how?
• Set in context not necessarily in that order!!
• The Elephants Child from Just So stories

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Wales Accord on theSharing of Personal
Information 2 The PISP

• Part D Kiplings Six Friends
• Who
• the partner organisations and job titles of staff
  involved
• What
• the personal information to be shared,
  Demographics, drugs/medication, circumstances
• the Key data fields that allow partners to know
  exactly who is being referred to, e.g. Name, i.d.
  number (social services, nhs, vol org)
• When
• describes when the information is exchanged, e.g.
  Weekly, daily, ad hoc team meeting, yearly

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Wales Accord on theSharing of Personal
Information 2 The PISP

• Part D Kiplings Six Friends contd.
• Where
• describes where each set of information is
  delivered, e.g. Safe haven, Email box, Shared
  Drive etc.
• Why
• describes the purpose of sharing each set of
  info.
• How
• describes how the information is collected, e.g.
  forms (including ref no.), system
• describes how the information is exchanged, e.g.
  letter, email, verbal, telephone includes
  enabling rules, laws etc. that need to be
  followed, and/or the titles of actual documents
  used by organisations

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Wales Accord on theSharing of Personal
Information 2 The PISP

• Appendix...
• Appendix are the sets of forms identified in part
  D
• These must be an authorised set
• Referenced
• Dated
• Version controlled

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Wales Accord on theSharing of Personal
Information

• for organisations involved in the
• health and social wellbeing
• of the people of Wales
• A Practical Approach to Information Sharing
• Finally

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Wales Accord on theSharing of Personal
Information

• Finally
• 1 The Accord only one of these
• (in the region)
• 2 The PISP describes the sharing
• The WWWWH
• (lots of these)

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Wales Accord on theSharing of Personal
Information

• Some challenges
• Getting everyone together
• 2 x 3 hr discussions
• Do it there and then
• Talk no email!
• Agreeing the information sharing community (not
  too big)
• Agreeing what can be shared
• Follow the service user path
• Central regional, organisational, govt. support
• Central regional resource for
• Co-ordination of Accord and PISPs
• Share experiences good ideas
• Help overcome difficulties

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Wales Accord on theSharing of Personal
Information

• What have we done the future
• in place since March 2007
• reviewed after 12 months
• PISPs developing info sharing community
• Welsh Assembly role to
• Act as central resource
• Co-ordinate development of PISPs
• Ensure implementation
• Share experiences
• Help overcome difficulties
• Share good things
• Manage internet pages

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Wales Accord on theSharing of Personal
Information

• Remember
• More than just sharing
• This is a framework not one document
• Everyone needs to be involved
• Were not inventing something new
• Its meant to be practical
• Its all about common sense

• Conclusion
• We know its not perfect
• Proof of pudding in eating
• Each organisation will need to cascade
• Each organisation will need to implement
• Use Information Governance Managers
• Not just for Wales
• For ALL services

PS.. Dont stop what youre doing now unless
its illegal!
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Wales Accord on theSharing of Personal
Information

• Extract from the Elephants Child by Rudyard
  Kipling
• I Keep six honest serving-men
• (They taught me all I knew)
• Their names are What and Where and When
• And How and Why and Who.
• I send them over land and sea,
• I send them east and west
• But after they have worked for me,
• I give them all a rest.
• I let them rest from nine till five.
• For I am busy then,
• As well as breakfast, lunch, and tea,
• For they are hungry men
• But different folk have different views
• I know a person small
• She keeps ten million serving-men,
• Who get no rest at all!
• She sends 'em abroad on her own affairs,

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Wales Information Sharing Design Team

• Accord on the Sharing
• of Personal Information
• for organisations involved in the safety, health
  social wellbeing of people
• A Practical Approach to Information Sharing