Introduction
The recent draft of Developing CCGs: Towards Authorisation sets out the proposed process for emerging Clinical Commissioning Groups (CCGs) to demonstrate their readiness to take on their statutory duties. This includes a proposed requirement to demonstrate that appropriate governance structures and processes are in place. This article considers the specifics of Information Governance (IG) and identifies the support and guidance available.
Background
Each CCG will be accountable for ensuring that it has adequate IG measures in place covering all aspects of information handling eg Information Security and Risk Management, Data Protection and Confidentiality, Information Quality and Corporate Records. The area which receives greatest media and public attention is the loss or inappropriate use of confidential patient information and recent legislation allows an organisation to be fined up to £500,000 for a serious breach of the Data Protection Act 1998. However, perhaps even more importantly, to discharge your CCG functions effectively you will need robust arrangements in place to support the effective and appropriate use of information.
Guidance and support
There are a range of existing tools, directives and guidance, which are available to help emerging CCGs demonstrate effective IG. In September 2011, Sir David Nicholson, NHS Chief Executive and Christopher Graham, the Information Commissioner published a joint letter aimed at all organisations that have access to NHS patient information. The letter highlights the continued need for robust IG, especially during the process of transition.
Linked to this letter, guidance for NHS Boards was also published in September 2011.
As a matter of policy all NHS and other organisations providing NHS services are required to complete and publish an annual assessment of IG performance using the NHS Information Governance Toolkit (IGT). This requirement is set out in national contracts for acute, community, mental health and ambulance services and has recently been incorporated within the national contract for pharmacy services.
Some 6,500 GP practices have provided IG assurance using this tool over several years and in March 2011 the General Practitioners Committee (GPC) advised practices to continue submitting IG Toolkit assessments (though it is not currently a contractual obligation for GPs). It is also necessary for organisations to demonstrate adequate IG before gaining approval to use national NHS systems eg connection to the N3 network.
The IGT is also home to a library of guidance and exemplar materials, including recently published guidance on Records Management During a Period Of Transition. This guidance provides advice on how to plan and approach the management of records during transition as well as FAQs, a flowchart to support decision making, details of where to find further information on how to manage records, and retention schedules broken down by SHA and PCT record types.
The IG Training Tool (IGTT) is a free online training resource which enables organisations to meet annual training requirements mandated for all of the public sector by government. Each CCG staff member can register an account, complete individual training and obtain certificate(s). There are currently over half a million user accounts across the NHS and organisations which support health and social care in UK.