If you have decided your concerns are mitigated after conducting your DPIA, you may want to implement an opt-out model as not everyone will want their records to be made available via the NHS app and website. You may still wish to adopt an opt-in approach for patients you have deemed as ‘high-risk’.

EMIS practices

If you have ‘gone live’

1. Advertise the opt-out model to all patients, and the opt-in model to those who had 104 codes applied to their records, encourage patients to sign up for the NHS app, and, for those who had 104 codes, once counselled, provision access manually for patients who request it.  Manual registration letters can be printed for those unable to sign up to the NHS app.
2. Update your practice website
3. Write to your ICB to inform them of your approach

If you have not yet ‘gone live’

1. Contact EMIS/your ICB to discuss a ‘go live’ date.
2. Ensure those patients deemed ‘at risk’ have 104 codes applied, and any patients who may previously have had a 104 code applied in bulk who are no longer deemed ‘at risk’ have that code rescinded through the addition of a 106 code (which would mean the 104 code is no longer active).
3. Advertise the opt-out model to all patients, and the opt-in model to those who have active 104 codes applied to their records, encourage patients to sign up for the NHS app, and, for those who have active 104 codes, once counselled, provision access manually for patients who request it. Manual registration letters can be printed for those unable to sign up to the NHS app.
4. Update your practice website
5. Write to your ICB to inform them of your approach

TPP practices

If you have ‘gone live’

1. Advertise the opt-out model to all patients, and the opt-in model to those who had 104 codes applied to their records, encourage patients to sign up for the NHS app, and, for those who had 104 codes, once counselled, provision access manually for patients who request it. Manual registration letters can be printed for those unable to sign up to the NHS app.

2. Update your practice website

3. Write to your ICB to inform them of your approach

If you have not yet 'gone live'

1. Ensure those patients deemed ‘at risk’ have 104 codes applied, and any patients who may previously have had a 104 code applied in bulk who are no longer deemed ‘at risk’ have that code rescinded through the addition of a 106 code (which would mean the 104 code is no longer active).
2. Advertise the opt-out model to all patients, and the opt-in model to those who have active 104 codes applied to their records, encourage patients to sign up for the NHS app, and, for those who have active 104 codes, once counselled, provision access manually for patients who request it. Manual registration letters can be printed for those unable to sign up to the NHS app.
3. Run the TPP-provided clinical report for accelerated access and then grant additional online services access to bulk provision access to those without active 104 codes.
4. Ensure that in the organisation preferences (in Online Services/Patient Record Access) the check box ‘By default give prospective access to the full clinical record’ in the ‘Full Clinical Record’ section is checked
5. Update your practice website
6. Write to your ICB to inform them of your approach

Any patients who do not have access and who have not opted out must be provided with access, subject to practices’ ordinary duties under data protection law not to disclose third party confidential information or information which could cause harm.