Dear Hywel Dda Local Health Board,

Hospital trusts are reportedly meant to keep a register of payments
from pharmaceutical companies (and other relevant companies) to
staff, in case of conflicts of interest [1].

I am requesting:

1. A copy of the register for this Trust.

Which I would hope includes details of all relevant payments to
staff and any related potential conflicts of interest. If it would be possible to have this information in an appropriate structured data format - for example, a CSV file - this would be helpful.

If this Trust does not have a complete register, I request:

1. the release of the information on this topic that the Trust does
hold.
2. An explanation of why the Trust does not hold a complete
register.

I am aware that some would view data on pharmaceutical funding as
personal data for those staff receiving the funding. Even if some
of the information on this register may be classed as personal data
(although this is contestable - for example, in some sectors of
academia information re funding sources is made public as a matter
of course) it would be covered by paragraph 6 of Schedule 2 of the
Data Protection Act. The release of these data is "necessary for
the purposes of legitimate interests pursued by the data controller
or by the third party or parties to whom the data are disclosed"
[2]. Spurling et al's systematic review of how information from
pharmaceutical companies impacts physicians' prescribing reported
that, of the studies included which looked at total promotional
investment, three "found that total promotional investment was
positively associated with prescribing frequency...Two...found both
positive results and no association...One study did not detect an
association" [3]. There is thus a legitimate interest in releasing
this register: the available research suggests that it is plausible
that payments received influence how public money is spent and the
type of care provided to members of the public.

For the reasons given above, there is a strong public interest in
releasing this information. While "requests for the personal data
of a third party are exempt under section 40(2) of the Freedom of
Information Act...if disclosure would contravene section 10 of the
Data Protection Act, the right to prevent processing likely to
cause damage or distress" [2], I would argue that, even if some of
those named in these documents feel that their release would cause
them damage or distress, this is outweighed by the significant
public interest served by releasing these data.

Yours faithfully,

David Carroll

[1]http://www.guardian.co.uk/society/2013/a...
[2]http://www.justice.gov.uk/downloads/info...
[3]http://www.plosmedicine.org/article/info...