NHS Digital has issued a DPN (data provision notice) as part of the development of GPDPR (GP data for planning and research). This is a planned replacement for the GPES (GP extraction service) to collect data for planning and research from general practices in England.
It is a legal obligation to comply with the DPN as a result of a new direction from the secretary of state for health and social care as part of the Health and Care Act 2012. Once fully established, this new collection will replace multiple other data collections from general practices.
NHS Digital has set out that, whilst general practice will still retain data controllership over patient records within their practice, once data has been extracted from patient records and shared with NHS Digital, NHS Digital will be the responsible and accountable data controller under the UK GDPR for data access and dissemination for planning and research.
Type 1 opt-outs will continue to be respected under GPDPR and a form for registering these can be found via the GP privacy notice which you will have received along with the DPN. The national data opt-out will not apply to the collection of this data by NHS Digital, as this is a collection which is required by law. However, it will be applied by NHS Digital on access or dissemination of data.
The BMA and RCGP, through our joint GP IT committee, have been engaged with the planning for this new collection over the past three years and made representations on behalf of GP practices to ensure stronger arrangements were put in place over the security and intended uses of the data collected.
GP data has a crucial role to play in research and planning which can improve public health, but it is important for patients and the public that this data is made available for appropriate purposes in a secure and trusted manner.
We are broadly supportive of the principles of the new collection in seeing fewer extracts of data and a reduced administrative burden for general practice.
It is also encouraging that the profession will continue to have oversight powers via the IGARD (independent group advising on the release of data) which advises NHS Digital, including formal BMA and RCGP representation through the professional advisory group.
We will continue to work closely with NHS Digital to ensure there are appropriate safeguards in place as to how the data collected under this new DPN is used, and to support the evolution of NHS Digital's trusted research environment in order to minimise the need to disseminate data to researchers.
You can read more about the GPDPR on the NHS Digital website.