· Web viewSanjay Gautama (Chair) welcomed everyone and asked them to introduce themselves. Formal apologies were received from Bill Sturman, Ernest Norman-Williams, John Keating

Minutes of the NW London CCGs Information Governing Group (IGG)15 MBR, Rooms 5.0/5.1

Thursday 6 December 2018, 09:30 to 13:00

Attendees:

Name Initials Role Organisation

Abhilash Abraham AA Head of IT Security & Governance NWL CCGs

Amanda Lucas ALu Programme Director ICHP (Discover)Andrew Layton ALa Solicitor Capsticks Solicitors LLP

Christine Dunne CD Deputy Director, Primary Care Systems NWL CCGs

Calum Leafe CL Assistant DPO Acute: ImperialCatherine Sewell CS IG Manager LNWUHDavid Grange DG IG Manager Patients Know Best (PKB)David Stone DS Managing Consultant Kaleidoscope ConsultantsFelix Vaal FV ICT Project Manager Acute: ImperialGaynor Lloyd GL Lay Member Co-opted by Governing GroupGraham Trainor GT Head of IG Acute: ChelWestIan Riley IR Director, BI NWL CCGs

Jan Boucher JB Tri-borough IG & Caldicott Support H&F Council

John Norton JN Lay Member Co-opted by Central London CCGKavitha Saravanakumar KSa Deputy Director, BI NWL CCGs

Dr Laurie Slater LS IG Lead NWL CCGsLisa Francis LF PMO Project Support NWL CCGsMike Bradford MB PMO Lead NWL CCGs

Muhitul Haque MH DCC Implementation & Training Lead NWL CCGs

Dr Murat Soncul MS IG Lead LHCRE MHT: South London & Maudsley

Dr Richard Baxter RB GP Lead (Co-Chair) Hounslow CCGRitu Sharma RS IG Manager Acute: THHDr Sanjay Gautama SG Clinical Director & Caldicott

Guardian Acute: Imperial

Serena Patel SP Solicitor Capsticks Solicitors LLP

1

Apologies:

Name Initials Role OrganisationBill Sturman BS Informatics Director NWL CCGsErnest Norman-Williams ENW DPO NWL CCGs

John Keating JK Deputy Director,: Programmes NWL CCGs

Mike Davies MD IT Strategy Lead NWL CCGs

Agenda (for the December Meeting)

Item Description Duration(mins) Owner(s)

1 Welcome, introductions and apologies 5 Sanjay Gautama2 Quoracy and declarations of interest 5 Sanjay Gautama

3 Minutes of previous meeting & actions 15 Sanjay Gautama

4 LHCRE Update 30 Dr Murat Soncul5 WSIC Update* 10 Ian Riley6 Digital ISA Update* 15 David Stone

7NWL Digital Data Protection Framework(including WSIC and CIE)

60 Sanjay Gautama & Calum Leafe

8 Implementation Update (including DCC) and Communication Update (including FPNs)* 15 Amanda Lucas,

Laurie Slater9 DCC Update 10 Muhutil Haque

10AOB: Felix Vaal; C&W Test Bed project Lisa Francis: January IGG Meeting?

10 All

Note: * The flagged agenda items were not discussed because of insufficient time.

1. Welcome, Introductions and Apologies Sanjay Gautama

Sanjay Gautama (Chair) welcomed everyone and asked them to introduce themselves. Formal apologies were received from Bill Sturman, Ernest Norman-Williams, John Keating and Mike Davies.

2. Quoracy and Declarations of Interest Sanjay Gautama

Not discussed.

3. Minutes of Previous Meeting and Actions Sanjay Gautama

The minutes for the IGG meeting held on 15 November 2018 were reviewed and approved.

2

The minutes are available here:https://www.healthiernorthwestlondon.nhs.uk/documents/wsic-dashboard/nwl-digital-isa-governing-and-advisory-bodies-minutes

Sanjay reviewed the open IGG actions from Aspyre and the action log was subsequently updated. The updated Aspyre action log can be found at the end of these minutes.

Actions closed during the previous (November) IGG meeting were deleted. Actions that were closed during the December IGG were retained on the action log but shaded grey to distinguish them from open actions. Open actions from November were carried forward and new actions from December were added.

4. LHCRE Update Dr Mural Soncul

Dr Murat Soncul, IG Lead for LHCRE, gave a verbal update on the IG Workstream of LHCRE.

Murat explained that the IG Team consisted of IG experts from North West London, East London and South East London. The IG Team had good engagement from other IG experts across London and beyond and included NHSD and NHSE.

ACTION: Murat Soncul to share the East London report on Data Driven Technology with IGG.

Murat explained that the main focus of the LHCRE IG group was cross learning and knowledge sharing for Health and for Social Care. A Steering Group has been set up with representation from NHSE and NHSD. A draft IG framework has been developed. The main focus is currently the development of an IG model which is being extended to encompass a wide range of stakeholders, including patients.

Murat added that the next steps were to produce a final version of the IG Framework with all five STPs represented. Where possible, existing IG collateral and expertise will be utilised. Work is in progress and the output will be shared with the IGG when it is ready. The technical architecture is being developed based on Cerner HIE.

The foundations and funding are in place. The initial priority is direct care with delivery planned for late 2019. The importance of clear, transparent and effective communications was recognised. Members of the IGG were invited to follow up with Murat individually, as required.

ACTION: Laurie Slater to meet Murat Soncul to discuss IG related communications and the sharing of primary care data.

ACTION: Sanjay Gautama to share his work on Information Sharing Agreements (ISAs) with Murat and LHCRE. This includes the new ISA framework and the associated processes.

5. WSIC Update Ian Riley

Not discussed due to insufficient time but the intended presentation is attached.

3

https://www.healthiernorthwestlondon.nhs.uk/documents/wsic-dashboard/nwl-digital-isa-governing-and-advisory-bodies-minutes

https://www.healthiernorthwestlondon.nhs.uk/documents/wsic-dashboard/nwl-digital-isa-governing-and-advisory-bodies-minutes

6. Digital ISA Update David Stone

Not discussed separately but ISAs were discussed in detail under agenda item #7.

7 Digital Data Protection Framework Sanjay Gautama, Calum Leafe

Sanjay Gautama gave an update on the NWL Information Sharing Agreement (ISA) and the associated NWL Digital Data Protection framework. A detailed conceptual model of the framework is attached:

Sanjay pointed out that the overarching framework sets out the sharing arrangements. It needs the signature of all parties. The overarching sharing statement is GDPR compliant. The IPA is an IG contract defining behaviour and how data is shared. It impacts WSIC and CIE. All data controllers must be clear on data sharing arrangements.

Serena Patel (Capsticks) added that the overarching ISA procedures are fit for purpose. They provide flexibility but clearly set out GDPR obligations. The IGG needs to sign off the DPA. The previous ISA presents a slight risk but is satisfactory. Some minor amendments may be needed to templates. A modular approach should be applied to the ISA. Compliance needs to be demonstrated by conducting DPIAs. More comprehensive legal requirements will be satisfied through Data Processing agreements. The ISA will need to be tailored for specific situations but is provides a satisfactory overarching framework.

Laurie Slater asked for clarification on whether formal signatures were needed for the ISA. Serena said that signature indicates agreement but that it was not necessarily a legal requirement. It was, however, good governance. Laurie further asked which parts of the ISA need a signature and which don’t. Sanjay reaffirmed that the overarching arrangement complies with the relevant laws. It may be possible to use the DCC to eliminate the need for signatures. The last layer needs a signature. GPs were advised to engage with their federations.

David Stone asked Capsticks whether the IGG could rely on their advice. Andrew Layton (Capsticks) responded by saying that Capsticks were commissioned by Imperial and that they could not speak for all parties.

Sanjay re-iterated that the overarching framework was a sound construct for managing direct care but emphasised that the IGG could only make recommendations. At the end of the day, individual parties had to make their own decisions. The existing ISA is still in place. If there are no material changes, the existing ISA can continue but anything “new” will need a “signature” (however defined). Clear, concise & effective communications were vital.

ACTION: Sanjay Gautama and Richard Baxter to formulate recommendations on how to amend the existing ISA to the new construct based on the legal advice they have received from Capsticks to make sure that it is legally sound.

ACTION: Sanjay Gautama and Richard Baxter to review the current terms of reference (ToRs) of the IGG and relate them to how the DCC works in terms of changes to the existing ISA. The ToRs should include the right to make recommendations on behalf of data controllers.

4

ACTION: Sanjay Gautama, Richard Baxter, Ian Riley & Bill Sturman to seek the approval of the Digital Portfolio Board (DPB) to extend the existing ISA arrangements to the end of June 2019.

ACTION: Laurie Slater and Richard Baxter to meet the Local Medical Committee (LMC) to seek their advice on the ISA,

ACTION: In order to validate the overarching framework, David Stone is to elaborate on the “inconsistencies and errors” he reportedly identified during his review of the framework and issue his findings to the IGG.

8 Implementation (DCC) and Communication (FPNs) Amanda Lucas, Laurie Slater

Not discussed. Update to be provided at next IGG Meeting. This is a standing agenda item, so it is not recorded as an action.

9 DCC Update Muhutil Haque

Muhitul Haque gave a status update on the Data Controller Console (DCC) project. For details see the attached presentation.

Muhitul pointed that 226 GPs were registered on DCC. The remaining 144 GPs not currently registered are being contacted. Three local authorities were engaged but the others had not yet responded, including the London Borough of Hounslow. Most CCGs had responded but not Ealing or Hounslow CCGs.

ACTION: Richard Baxter to contact the London Borough of Hounslow and Hounslow CCG to get them engaged with DCC

Muhitul gave an update on the associated eLearning self-training. It was planned that 80% of the self-training would be completed by the end of December 2018 and 100% by the end of March 2019.

Jan Boucher pointed out that Hammersmith & Fulham were having major issues connecting with DCC. Imperial needed to be trained on DCC.

ACTION: Muhitul Haque to investigate the problems Hammersmith & Fulham were having connecting to DCC and rectify.

ACTION: Muhitul Haque to contact Philip Robinson at Imperial to organise DCC training.

5

10 AOB Sanjay Gautama

10.1 Test Bed Project Felix Vaal

Felix Vaal [pointed out that the C&W Test bed project was dependent on the ISA with PKB. He asked that the present agreement with PKB be extended to end June 2019. It was pointed out that the IGG needed to understand the scope of the project and need to see the documentation before agreeing the extension.

ACTION: Felix Vaal to provide the IGG with the relevant C&W Test Bed project documentation, including the data flows and scope.

10.2 Next IGG Meeting: Lisa Francis

It was agreed that the IGG for January 2019 would be cancelled. The next IGG will be in February 2019.

ACTION: PMO to cancel the January 2019 IGG and set up the February meeting.

Sanjay Gautama closed the meeting.

11 Next Meeting All

The next meeting will take place from 09:30-12:30 on 7 February 2019 at 15 Marylebone Road

6

Programme/Project/Org Name

ID Action Update Owner(s) Status Date Created

Target Date

Actual Date

IG & Cyber Security Steering Group

0031 London North WestIR agreed to write to SP to confirm her preferred treatment of active and newly trained users.

Update 06/12/2018 (MB): Action Closed

03/10/18 (LF): This action has been taken by the chair Sanjay, Sanjay said he will be in touch with Sonia and give an update on LNWHT

Sanjay Gautama Closed 07/12/17 01/03/18 6/12/18


0049 Requests for IG support.ACTION:It was agreed that there needed to be a meeting with ICHT and other stakeholders before the project could progress. This meeting should include project and ICHT. LS and Christine Dunne should be copied in so they were aware of progress.

6/12/2018: Update MBSG+RB+IR to meet BS to agree next steps.

Richard Baxter, Laurie Slater, Sanjay Gautama

Open 18/01/18 15/11/18


0054 De identified request for Information Manager (WSIC programme)ACTION:The IGG agreed that it was a reasonable request. Given that it was already a recommendation from the DSA sub group (albeit non-quorate) it was agreed that it would be considered as Chair’s action after the meeting and then reported to the next GG.

Update 06/12/2018 (MB): Action Closed

29/10/18 (LF): This action is carried forward as Sanjay was unable to attend the October IG meeting.

Sanjay Gautama Closed 18/01/18 15/11/18 6/12/18

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Target Date

Actual Date


0056 QUORACYISA project team to consider terms of reference of future governing group and consider mechanisms for using available technology to allow for more efficient and robust ways of communicating with a wider group of signatories.

Update 06/12/2018 (MB): Carry forward.

29/10/18 (LF): This remains an open action.

Open 01/02/18


0060 BREACHESEN-W to bring a report on any breaches to the Governing Group and report on actions taken to ensure there are systems in place so this happens in future.

Update 06/12/2018 (MB): Action Closed 03/12/18 (LF): This action can be closed as it forms part of BAU.

Ernest Norman-Williams

Closed 01/02/18 01/02/18 06/12/18


0061 CIE PROGRAMMESJ to return to the GG with a report on the programme in primary care and giving access to patients.

Update 06/12/2018 (MB):Action Closed

Stephen Janering Closed 01/02/18 05/04/18 06/12/18


0066 PKB PRIVACY NOTICEPKB (DG) to circulate the privacy policy as a ‘below the line’ paper to a future meeting with the change to PN highlighted.

Update 06/12/2018 (MB):RB to circulate.

01/03/18 (LF): PKB will bring to the meeting when ready

Open 01/02/18 01/03/18


0108 NEXT STEPS FOR DSP. Sanjay Gautama and Ian Riley to meet with Bill Sturman to discuss what should happen now to bring the approach and the drafting to an early close. David Stone should not do further work until advised.


Ian Riley, David Stone

Closed 25/09/18 04/10/18 6/12/18

8



Target Date

Actual Date


0113 Update on activities from the Data Flows, Security and Access (DSA) Sub-Group ACTION:NEW ACTION: Raj Seedher to set up a working group to review the Terms of Reference for the DSA to ensure its compliance with GDPR. Raj to present the findings at the next IGG


Raj Seedher Closed 11/10/18 01/11/18 6/12/18


0114 Review of actions log:ACTION: Richard Baxter, Sanjay Gautama and Laurie Slater to meet to discuss the dynamics and governance of the IGG in relation to other NWL governance forums. Terms of Reference are to be reviewed. Findings to be presented at a future IGG Meeting

Update 06/12/2018 (MB):Not actioned. Leave open.

Richard Baxter, Laurie Slater, Sanjay Gautama

Open 11/10/18 01/11/18


0116 Discover programme: Detailed briefingACTION: Amanda Lucas to reissue her paper on the Discover Data Security Model to the IGG.

Update 06/12/2018 (MB):Action closed.

Amanda Lucas Closed 11/10/18 01/11/18

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Target Date

Actual Date


0117 Information Sharing Agreement ACTION: Sanjay Gautama to get a second legal opinion (to that provided by DAC Beachcroft) on whether the ISA should be formally signed or simply acknowledged.Richard Baxter said that sight was needed of the IG work being carried out under LHCRE. An update was also needed on the status of the Data Controller Console (DCC) and the possible impacts of the new ISA.

Update 06/12/2018 (MB):Action closed

Sanjay Gautama Closed 11/10/18 01/11/18


0118 DCCXavier Yibowei to give a status update on the DCC at the next IGG meeting.

Update 03/12/18 (LF): This is on the December Agenda Muhitul Haque will be giving the update. Action closed..

Xavier Yibowei Closed 11/10/18 06/12/18 06/12/18


0119 LHCRERichard Baxter to discuss LHCRE with Bill Sturman. Bill Sturman to give an update on LHCRE and IG at the next IGG Meeting.

Update 03/12/18 (LF): Bill Sturman was unable to attend the November meeting but the LHCRE is an agenda item at the December 2018 meeting. Action closed..

Richard Baxter Closed 11/10/18 01/11/18 06/12/18


0120 Implementation (including DCC) and Communication (including FPN) ACTION Amanda Lucas to work with Laurie Slater to review Trust and Borough FPNs in relation to Discover and present gaps at the next IGG Meeting.

Update 03/12/18 (LF): This is a December 2018 Agenda Item. Action closed.

Amanda Lucas, Laurie Slater

Closed 11/10/18 06/12/18 06/12/18

10



Target Date

Actual Date


0122 Update on Data Support projectACTION: Laurie Slater and Christine Dunne to present the GP GDPR compliance processes to the eight CCGs.

Update 06/12/18 (MB): Action closed

Christine Dunne, Laurie Slater

Closed 11/10/18 01/11/18 06/12/18


0123 Any other businessACTION: Bill Sturman to invite Dr Murat Soncu, who is leading on IG for One London LHCRE, to the next IG Meeting

Update 03/12/18 (LF):This action can now be closed, Dr Murat Soncu, has been invited and this is an item on the December 2018 agenda. Action closed..

Bill Sturman Closed 11/10/18 01/11/18 06/12/18


0125 Digital ISA updateACTION: David Stone to review the draft NW London Digital Data Protection Framework and the associated ISA to ensure that it satisfies all necessary legal requirements. David Stone is to report back to the December IGG meeting

Update 03/12/18 (LF): This is on the agenda for the December 2018 meeting. Action closed.

David Stone Closed 15/11/18 06/12/18 06/12/18


0126 DPIA For WSICACTION: Kavitha Saravanakumar to arrange a full DPIA to be conducted on WSIC. This includes Christine Dunne to amend the Privacy Notice template to include and explanation of what cloud is and how cloud will be used (previously action #0127).

Update 03/12/18 (LF): An update to this action will be provided at the Jan 2019 meeting.

Kavitha Saravanakumar

Open 15/11/18 03/01/19


0127 DPIA for WSIC.ACTION: Christine Dunne to amend the Privacy Notice template to include and explanation of what cloud is and how cloud will be used.

Update 06/12/18 (MB): Action merged with 0126 and closed.

Christine Dunne Closed 15/11/18 03/01/19 06/12/18

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Target Date

Actual Date


0128 Implementation (including DCC) and Communication (including FPN) ACTION: Christine Dunne to discuss the possible need for a London wide approach to IG related communications for London (via LHCRE) with Bill Sturman and ask him if he can provide any possible exemplars

Update 03/12/18 (LF): This action can be closed as Dr Murat Soncu will attend to discuss the London wide approach to IG.

Christine Dunne Closed 15/11/18 03/01/19 06/12/18


0129 DPIA for Tele-Dermatology (Part of Out Patients Programme)ACTION: 1 The IGGG is to provide feedback to Mike Davies on possible IG/GDPR implications for Tele-Dermatology by end of November. ACTION: 2 Mike D to collate responses and report back to a future IGG

Update 03/12/18 (LF):Action 2: Mike D will provide an update at the Jan 2019 Meeting.

Mike Davies, _ All Open 15/11/18 03/01/19


0130 AOB from meeting in November 2018ACTION: Laurie Slater to ask CCG Chairs to appoint DPO's and provide a suitable cyber security service.

Update 06/12/18 (MBNo change. Carry forward.

Laurie Slater Open 15/11/18 06/12/18


0131 Breaches to be actively brought to IGG

Update 06/12/18 (MBNo change

All Open 15/11/18 Next IGG


0132 Share the East London report on Data Driven Technology with IGG

Update 06/12/18 (MB)New

Murat Soncul New 06/12/18


0133 Meet Murat Soncul to discuss IG related communications and the


Laurie Slater New 06/12/18

12



Target Date

Actual Date

sharing of primary care data.


0134 Share the work on Information Sharing Agreements (ISAs) with Murat Soncul and LHCRE. This includes the new ISA framework and the associated processes.


Sanjay Gautama/ Philip Robinson

New 06/12/18


0135 Formulate recommendations on how to amend the existing ISA to the new construct based on the legal advice they have received from Capsticks to make sure that it is legally sound.


Sanjay Gautama/ Richard Baxter

New 06/12/18


0136 Review the current terms of reference (ToRs) of the IGG and relate them to changes to the existing ISA. The ToRs should include the right to make recommendations on behalf of data controllers.


Sanjay Gautama/ Richard Baxter

New 06/12/18


0137 Seek the approval of the Digital Portfolio Board (DPB) to extend the existing ISA arrangements to the end of June 2019.


Sanjay Gautama/ Richard Baxter/Ian Riley/Bill Sturman

New 06/12/18


0138 Meet the Local Medical Committee (LMC) to seek their advice on the ISA,


Laurie Slater/ Richard Baxter

New 06/12/18


0139 In order to validate the overarching framework, David Stone is to elaborate on the “inconsistencies and errors” he reportedly identified during his review of the framework and issue his findings to the IGG.


David Stone New 06/12/18

13



Target Date

Actual Date


0140 Contact the London Borough of Hounslow and Hounslow CCG to get them involved in DCC.


Richard Baxter New 06/12/18


0141 Investigate the problems Hammersmith & Fulham are having connecting to DCC and rectify.


Muhitul Haque New 06/12/18


0142 Contact Philip Robinson at Imperial to organise DCC training


Muhitul Haque New 06/12/18


0143 Provide the IGG with the relevant C&W Test Bed project documentation, including the data flows and scope.


Felix Vaal New 06/12/18


0144 PMO to cancel the January 2019 IGG meeting and set up the February meeting.


Lisa Francis New 06/12/18

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Documents

· Web viewSanjay Gautama (Chair) welcomed everyone and asked them to introduce themselves. Formal apologies were received from Bill Sturman, Ernest Norman-Williams, John Keating