data security and protection toolkit questions

Q. I currently maintain a comprehensive list of the hardware and software I own for insurance purposes. The NHS requirements relate only to protecting patient identifiable information therefore Requirement 116 relates only to the contracts of contractors who have access to patient identifiable information, for example PMR suppliers. Do I need to register with the Information Commissioner’s Office? For example: “Requirement not applicable, this pharmacy does not use removable or portable computing equipment including CDs/DVDs and USB sticks.” The pharmacy should ensure that staff do not use mobile computing devices in their role. In the pharmacy’s records, it would be acceptable to document a position, for example, ‘the pharmacy manager’ or ‘Clinical Governance Lead’ rather than a named individual, as long as the staff member(s) concerned are clear from this that they are responsible and it is clear to other staff who the IG Lead is. A. This requirement relates to safeguarding mobile devices that are used to store personal information. How can I assess the risk of a particular flow? Any improvements in the scores should be entered into the next version of the Information Governance Toolkit. Data Security, IG and Toolkit frequently asked questions. Do I need to declare this in my Information Asset Register? The DSP toolkit (also known as the data security and protection toolkit) is an online self assessment tool that enables organisations to measure and publish their performance against the National Data Guardian’s ten data security standards.You can access the toolkit … But there may be differences depending on the nature of services provided under the LPS, therefore we recommend discussing this with your local NHS England team. A. A.  Given that both contracts are linked to the same premises, it may be appropriate to have only one submission which provides assurances to the on the management of information obtained under both contracts at the premises. There are a number of exceptional circumstances in which personal data can be disclosed without patient consent, for example, where disclosure of personal data is necessary to prevent serious injury or damage to the health of a patient. Q. Pharmacies should use their judgement based on local circumstances on which pieces of hardware should be recorded on the asset register.   Data security standards - big picture guides. Data security standards - big picture guides, 6.1. •Changes have been … e-Learning – data security awareness – level one (v3.0), 3. Therefore, before faxing a prescription to a manufacturer, any information that could be used to identify the patient must be obscured / redacted in black ink unless the patient has consented to their personal data being disclosed. What happens if I don’t complete my submission by the deadline? The ICO recommends that portable and mobile devices including magnetic media, used to store and transmit personal information, the loss of which could cause damage or distress to individuals, should be protected using approved encryption software which is designed to guard against the compromise of information. Q. Guidance on notification can be found on page 47 of the Pharmacy Contractor Workbook and the ICO have further information. ... Data Security and Protection Toolkit … If you have queries on this webpage or you require more information please contact it@psnc.org.uk. Q. I have had a call from a local police station. Two identical pharmacies holding the same information, computers and stock may have quite different physical security needs if one is located in an area of high crime and the other in a low crime area. Q. A. The level of risk is normally established by considering the impact of a data loss and the likelihood of that loss taking place. A. A number of changes were made to the Terms of Service requirements (Clinical Governance) in October 2011 to require pharmacies to comply with an approved information governance programme. Q. I run a wholly mail order business. This information should not normally be in the public domain. By 31st March 2011, all pharmacies are required to make a leaflet available with comprehensive information on how patient information is used by the pharmacy. Entry Level Evidence items (2020-21), 4. Data Security and Protection Toolkit staff awareness questions For a multiple pharmacy, when registering for access to the IG Toolkit, is it possible to register using the same name and log-in email for each premises and just change the ODS code? The manufacturer is requesting that I share the prescription form serial number. On the template ‘Portable Equipment: Asset Control Form’, there is a section for “Asset number” and “Mobile number”. When can I next submit an assessment? A. Pharmacies are required to make an annual assessment. Both are linked to the same premises. £90 million of investment was agreed for these unavoidable one-off infrastructure costs. For example, if the laptop connects to the pharmacy network and is used to access the internet, one risk is that if the anti-virus on the laptop isn’t updated regularly, the laptop could introduce viruses to the local network that could compromise the security of information held on other computers connected to the network. Do the requirements apply to hardcopy data e.g. All organisations that have access to NHS patient data and systems must use the toolkit to provide assurances that they are practising good data security and that personal data is handled correctly. The risk level needs to be kept under review as circumstances change. The Data Security and Protection Toolkit is an online self-assessment tool that allows organisations to measure their performance against the National Data Guardian’s 10 security standards. If so, only the minimum amount of personal data necessary should be disclosed. Queries on specific IG requirements can be found towards the bottom of the page. name, address, dob etc. A. Does this mean I must comply, or should I withhold patient details? How to find us The 2010/11 community pharmacy contractual framework funding settlement included provision for the costs of PC renewal in community pharmacies. A contractor would have to review the template and consider whether they were sufficiently relevant to local circumstances, adapting the templates where necessary. Q. I have both an LPS Contract and a General Pharmaceutical Services contract. Q. What does “data processed outside of the UK” relate to? The guidance for this requirement states, “Patient identifiable information stored on a PC hard drive or other removable device in a non-secure area or on a portable device such as a laptop, PDA or mobile phone should be encrypted. The guidance states that, “There have been a number of reports recently of laptop computers, containing personal information which have been stolen from vehicles, dwellings or left in inappropriate places without being protected adequately. Regulatory burdens are assessed on a retrospective basis and included in funding negotiations. Data Security and Protection Toolkit on a spreadsheet, 6.2. If you have a support query, please contact us at https://www.dsptoolkit.nhs.uk/Home/Contact. To date £12m has been allowed. This would be for the contractor to decide and is outwith the scope of the NHS requirements. Pharmacies are also required to be compliant with data protection legislation and the NHS Code of Practice on Confidentiality. On the Information Governance Toolkit, there are fields linked to each requirement to record the location of evidence or to upload evidence. Q. The Information Commissioner’s Office has issued guidance on their approach to encryption. Use our form to help you answer 12 questions. broadband connectivity). How often should the pharmacy IG policies and procedures be updated? A. Before disclosing patient data, pharmacists would need to satisfy themselves that the person requesting the data is properly authorised under the Misuse of Drugs Act and that the request for information is consistent with the carrying out of routine checks. The ICO has published guidance on what they consider to be ‘reasonable steps’. This survey has been developed by NHS Digital to assist organisations in understanding the data security awareness of its staff. Data Security and Protection Toolkit staff awareness questions, 7. Return to the section: Data security and information governance, Return to the section: Data Security and Protection Toolkit, Return to the Pharmacy IT hub or IT a-z index. Q. The Information Commissioner has formed the view that in future, where such losses occur and where encryption software has not been used to protect the data, regulatory action may be pursued. If a decision is made to disclose without consent, an accurate record must be made of: who the request came from, the reasons for releasing the data without consent, whether you attempted to obtain patient consent, and if not why not, why patient consent was refused and what information was disclosed. checking with your PMR supplier that any personal data transmitted electronically remains in the UK). The Data Security Protection Toolkit – and accompanying guidance – have been reviewed to make them more relevant, practical and easier for care providers to use. It is now possible for a Head Office staff member to centrally view the submissions of individual stores through a central log-in. A. To update details users need to log-in and then select the ‘Organisation Profile’. It is for a contractor to assess the risk they face based on local circumstances. The DSPT will help evidence your compliance with data protection legislation (General Data Protection Regulation or GDPR and Data Protection … Are the template SOPs good enough to comply with the NHS Requirements? should not normally be disclosed without patient consent or otherwise allowed by law. This outlines the entry level Data Security and Protection Toolkit evidence items. Q. If there are flows outside of the UK, it is important to undertake an appropriate risk assessment and put in place mitigating controls, for example contractual requirements on the supplier. If a pharmacist is interrupted part-way through recording information against an individual requirement, click the ‘save’ button and work done will be saved. Although it is accepted that for practical reasons the role may need to be assigned to a position in some scenarios, where possible, best practice is that the lead is a named individual. Q. However the pharmacy may still find benefits in doing this for other reasons, for example to minimise the risk of theft. The account of the previous owner can be locked and the new owner registered against that ODS Code. Some of the NHS IG requirements therefore have a specific focus on either digital or hardcopy information. Q. I have heard that I need to encrypt my computers to reach level 2 of the NHS Information Governance Toolkit. This includes things like putting in place appropriate policies and procedures, undertaking risk assessments and putting in place appropriate mitigation to safeguard data and having good governance/audit arrangements to prevent contraventions of data protection regulations. A. Does the IG lead have to be a named individual (for example “Fred Bloggs”) or can it be a position (for example “Pharmacy Manager”)? The intention of the ‘mobile number’ field was to record mobile phone numbers however note that under this requirement, it is only necessary to track mobile phones that are being used to store personal information. Q. I have received an FP10 prescription for an unlicensed “named patient supply” product. They have undergone two phases of consultation led by the PSNC. A. A number of manufacturers are requesting that contractors fax anonymised copies of prescriptions before stock is released. No. There are a number of different commercial options available to protect stored information on mobile and static devices and in transmission, such as across the internet.”. Note, it is a legal requirement through data protection legislation to make “fair processing information” available. To register for the IG Toolkit, I need to provide my email address. There is a risk of some solutions slowing down or interrupting the operation of the PMR system if the solution isn’t tested or if implementation isn’t properly managed. The Data Security and Protection Toolkit uses cookies to improve your on-site experience. On the 1st April 2013, responsibility for monitoring and supporting pharmacy information governance passed from PCTs to NHS England Area teams (now local NHS England teams). General Practice however there may be alternative questions relevant to just your organisation type: Complete each question as instructed and click on Continue when answered. Once I’ve registered for the IG Toolkit, how do I update my registered email address or other information? If a pharmacy has not notified the ICO, this would be a breach of data protection legislation and a criminal offence. 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