Linkage of CHI and pupil numbers: PIA and privacy approval
Dear NHS National Services Scotland,
Researchers from the Information Services Division, NHS National Services Scotland, and other Scottish institutions recently published a study based on the linkage of CHI and pupil numbers of all pupils in publicly funded schools in Scotland [1].
I should be grateful if you would provide me with the Privacy Impact Assessment for this study along with any other information and documentation related to assessment of the privacy implications of this study and the consideration and approval of this study by governance boards.
Yours faithfully,
Dr. Geraint Bevan
NO2ID Scotland
[1] D. Clark, A. King, K. Sharpe, G. Connelly, L. Elliott, L.M.D. Macpherson, A.D. McMahon, I. Milligan, P. Wilson, D.I. Conway, R. Wood, Linking routinely collected social work, education and health data to enable monitoring of the health and health care of school-aged children in state care (‘looked after children’) in Scotland: a national demonstration project, In Public Health, Volume 150, 2017, Pages 101-111, ISSN 0033-3506, https://doi.org/10.1016/j.puhe.2017.05.003.
(http://www.sciencedirect.com/science/art...)
Keywords: Child in care; Looked after children; Delivery of health care; Dental health services; Medical record linkage; Public health informatics; Scotland
Dear Dr Bevan,
Freedom of Information Reference: FOI-2017-000389
I refer to your freedom of information request which we received on 20
November 2017, requesting the following information:
· Researchers from the Information Services Division, NHS National
Services Scotland, and other Scottish institutions recently published a
study based on the linkage of CHI and pupil numbers of all pupils in
publicly funded schools in Scotland [1].
I should be grateful if you would provide me with the Privacy Impact
Assessment for this study along with any other information and
documentation related to assessment of the privacy implications of this
study and the consideration and approval of this study by governance
boards.
I confirm that under the terms of the Freedom of Information (Scotland)
Act 2002, a response to your information request will be sent within 20
working days of receipt, i.e. no later than 18 December 2017.
Kind regards
Nicola Cuthbertson
NHS National Services Scotland
Information Governance Support Officer
Strategy and Governance Directorate
Area 27, Ground Floor
1 South Gyle Crescent
Edinburgh, EH12 9EB
NHS Website: [1]http://nhsnss.org/
4 Please consider the environment before printing this email.
NHS National Services Scotland is the common name for the Common Services
Agency for the Scottish Health Service. [2]www.nhsnss.org
Cc for Information
Dear Dr Bevan
Clarification request - FOISA request reference: FOI-2017-000389
Thank you for contacting NHS National Services Scotland (NSS). I write
further to your request under the Freedom of Information (Scotland) Act
2002, received by NHS National Services Scotland (NSS) Monday 20 November
2017.
I have been passed the request to progress within our NSS Public Health
and Intelligence strategic business unit. Part of National Services
Scotland that comprises NSS Information Services Division (ISD) and NSS
Health Protection Scotland (HPS).
In your request you have asked NSS for the following:
“Researchers from the Information Services Division, NHS National Services
Scotland, and other Scottish institutions recently published a study based
on the linkage of CHI and pupil numbers of all pupils in publicly funded
schools in Scotland [1].
I should be grateful if you would provide me with the Privacy Impact
Assessment for this study along with any other information and
documentation related to assessment of the privacy implications of this
study and the consideration and approval of this study by governance
boards.”
Having reviewed your information request, I regret that it is unclear
precisely what information is being requested.
As I have been unable to contact you by phone to clarify your request, I
would therefore request that you contact me on:
Phone: 0131 275 7867
Email: [email address]
Address: PHI FOI Support Co-ordinator, NHS National Services
Scotland, NSS Public Health & Intelligence, Gyle Square, 1 South Gyle
Crescent, Edinburgh EH12 9EB
I will not be able to take this matter further without extra information
from you. In particular, it would be useful to know the reference for the
study that your referenced in the email, the date of the publication (if
known) and any further that detail that would enable be to locate the
information from the records we hold.
We consider that this request is paused until you kindly respond back to
provide the requested clarification.
With thanks.
Regards,
Kiri Brown
PHI FOI Support Co-ordinator (Miss)
Statistical and Information Governance Team
Information Services Division (ISD)
NHS National Services Scotland
NSS Public Health & Intelligence
Gyle Square I 1 South Gyle Crescent I Edinburgh I EH12 9EB
Dear PHI-FOI (NATIONAL SERVICES SCOTLAND),
The article referred to in my request is:
D. Clark, A. King, K. Sharpe, G. Connelly, L. Elliott, L.M.D.
Macpherson, A.D. McMahon, I. Milligan, P. Wilson, D.I. Conway, R. Wood,
Linking routinely collected social work, education and health data to
enable monitoring of the health and health care of school-aged children
in state care (‘looked after children’) in Scotland: a national
demonstration project,
In Public Health, Volume 150, 2017, Pages 101-111, ISSN 0033-3506,
https://doi.org/10.1016/j.puhe.2017.05.003.
http://www.sciencedirect.com/science/art...
From the section on "Ethical approval":
Approval for this study was obtained from the Scottish Government Education Analytical Services Division Data Access Panel and the NHS Privacy Advisory Committee (now the Public Benefit and Privacy Panel). The approval processes involved completion of a privacy impact assessment, a data sharing agreement between the Scottish Government and the University of Glasgow, and a data processing agreement between the University of Glasgow and the NHS National Services Scotland Information Services Division. Ethical approval was obtained from the University of Glasgow College of Medicine, Veterinary, and Life Sciences Ethics Committee: NHS ethical approval was not required.
Yours sincerely,
Dr. Geraint Bevan
Cc for Information
Dear Geraint
Thank you for your phone call and for sending this information regarding the study mentioned in your request.
I think that this information will be enough to provide clarification necessary to progress our search for relevant information.
A further response will be sent as soon as possible, and not later than 21 December 2017.
Right to Review
If you are unhappy with any aspect of how we have dealt with your request, you can make representation to us within 40 working days of the date of this correspondence asking us to review the handling of your request. Please write to:
Associate Director of Corporate Affairs and Compliance NHS National Services Scotland Headquarters Gyle Square
1 South Kyle Crescent
Edinburgh EH12 9EB
If after the review you are still unhappy, you should then have the right to apply to the Scottish Information Commissioner who can be contacted at Kinburn Castle, St Andrews, Fife KY16 9DS or via their online application form.
With thanks,
Regards,
Kiri Brown
PHI FOI Support Co-ordinator
Statistical and Information Governance
NHS National Services Scotland
NSS Public Health & Intelligence
Gyle Square I 1 South Gyle Crescent I Edinburgh I EH12 9EB
Gyle Square
1 South Gyle Crescent
Edinburgh EH12 9EB
ISD Scotland I 0131 275 7867 I NHS National Services Scotland I [email address]
X 11 attachments, PDF documents.
Dear Dr Bevan
Freedom of Information reference: FOI-2017-000389
I write in response to your Freedom of Information Scotland Request dated
20 November
2017.
“Researchers from the Information Services Division, NHS National Services
Scotland, and other Scottish institutions recently published a study based
on the linkage of CHI and pupil numbers of all pupils in publicly funded
schools in Scotland [1].
I should be grateful if you would provide me with the Privacy Impact
Assessment for this study along with any other information and
documentation related to assessment of the privacy implications of this
study and the consideration and approval of this study by governance
boards.”
Thank you for your contact in respect of further clarification, in our
phone call of 23 November
2017. The study referred to was clarified by you as follows:
A study based on the linkage of CHI and pupil numbers of all pupils in
publicly funded schools in
Scotland. I include the link here and details to the study published
online:
D. Clark, A. King, K. Sharpe, G. Connelly, L. Elliott, L.M.D.
Macpherson, A.D. McMahon, I. Milligan, P. Wilson, D.I. Conway, R. Wood,
Linking routinely collected social work, education and health data to
enable monitoring of the
health and health care of school-aged children in state care (‘looked
after children’) in Scotland: a
national demonstration project,
In Public Health, Volume 150, 2017, Pages 101-111, ISSN 0033-3506,
[1]https://doi.org/10.1016/j.puhe.2017.05.003.
[2]http://www.sciencedirect.com/science/art...
I am pleased to provide
* A summary from the researchers regarding the permission they
obtained before
carrying out their work
* The Privacy Impact Assessment they refer to in their summary
* Copy of the letter of approval from the ethical Committee of
Glasgow University
College of Medical Veterinary and Life Sciences
* Privacy Advisory Committee: Description of the processes
undertaken by NSS to
consider privacy and public interest in work requesting access to data in
NSS control.
Until 2015 this was by internal assessment and obtaining advice from a
mainly lay
Privacy Advisory Committee to the NSS Board.
* The Privacy Advisory Committee application from the research
team
* Application supporting documentation which include:
o Data sharing agreement with SG and University of Glasgow
o Data processor agreement University of Glasgow and NSS
o Letter from scientific officer West of Scotland Research
Ethics Service
confirming no ethical approval required
* documents relating to PAC processing
including the
o Proportionate governance checklists completed by ISD
Caldicott Guardian and
Data Protection Lead and NSS Information Security Advisor
o Summary Checklist with description of the application,
assessment by ISD Caldicott Guardian and Data Protection Lead
and NSS Information Security Advisor, PAC members approvals and comments
* Privacy Advisory Committee letter of approval
For five of the documents we are providing we have considered it
appropriate to redact the names of some individuals. This has been done on
the basis that it is their job role, rather than personal detail that is
relevant to their contribution.
I highlight that the names of senior staff, as well as those names that we
consider are already in the public domain, as part of the study published
(referenced above) are included, and released to you without redaction.
For those names where we have taken the decision to redact, I can advise
that we consider that an exemption applies, under the Freedom of
Information (Scotland) Act 2002. The exemption we consider to apply is:
Personal Information - section 38 (1) (b). This is an absolute exemption
and as such is not subject to the public interest test.
Please contact me on [3][email address] or 0131 275 7867 with any
questions regarding our email response to your request.
Right to Review
If you are unhappy with any aspect of how we have dealt with your request
you can make
representations to us asking us to review the handling of your request.
Please write to the
Associate Director of Corporate Affairs and Compliance, NHS National
Services Scotland,
Headquarters, Gyle Square, 1 South Gyle Crescent, Edinburgh, EH12 9EB
within 40 working
days of the date of this correspondence.
If after a review you are still unhappy, you also have the right to apply
to the Scottish
Information Commissioner, who can be contacted at Kinburn Castle, St
Andrews, Fife, KY16
9DS, or via their online Appeal form.
Yours sincerely,
Kind regards,
Kiri Brown
PHI FOI Support Co-ordinator
Statistical and Information Governance Team
Information Services Division (ISD)
NHS National Services Scotland
NSS Public Health & Intelligence
Gyle Square I 1 South Gyle Crescent I Edinburgh I EH12 9EB
Telephone: 0131 275 7867 I Email: [4][email address] I
[5]www.isdscotland.org
Public Health and Intelligence includes Health Protection Scotland (HPS)
and the Information
Services Division (ISD), and is part of NHS National Services Scotland
NHS National Services Scotland is the common name for the Common Services
Agency for the
Scottish Health Service. [6]www.nhsnss.org
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