NHSX sets out new Information Governance Framework on Shared Care Records

NHSX’s framework on Shared Care Records (ShCRs) is for Information Governance professionals (IG), designed to provide a structured approach to ensure ShCRs meet their legal obligations. This includes when they are planning, preparing and delivering data sharing.

The aim of ShCRs is to support organisations move from today’s position, where each organisation holds separate records for the individuals they care for, to one where an individual’s record is shared across the health and care system in a safe and secure way. ShCRs was previously known as the Local Health and Care Records (LHCR) programme.

ShCRs is based on a model where controllership remains local, with local agreements in place to set out what data is shared and who can access it in a safe, secure and appropriate manner.  The framework explains that this approach recognises the variance in how data is captured and represented in local systems.

Using the IG framework

The framework is structured around “journeys”, with “journey 1” covering the sharing of personal confidential patient information between health and social care bodies within a ShRC for the individual care of patients and “journey 2” covering the sharing of patient information between health and social care bodies but across geographical boundaries.

A set of requirements is outlined that covers both journeys and a specific set or requirements for each of the journeys. The detailed framework at 67 pages also includes journey pathways with example task lists to support IG professionals consider their data protection requirement prior to undertaking the processing of personal data. Seven appendices are included to support with issues such as assurance checklists, data breach management, individual rights and a range of other tools and templates.

The bigger picture

NHS England and Improvement has made it clear in their recently published ICS design Framework that by April 2022 each ICS needs to “implement a shared care record, that allows information to follow the patient and flow across the ICS to ensure that clinical and care decisions are made with the fullest of information.”

So how have shared cared record systems progressed up to this point? This very much depends on which area you are talking about. Areas such as Greater Manchester already have a well-established footprint with the GM Care Record. Others are some way off digitising the information in order to get to a point where it can be shared more easily.

If you’d like would like support on the legal and regulatory issues relating to digitising and sharing health and care information please do get in touch.

Charlotte Lewis and Sophie Burton-Jones

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Every piece of content we create is correct on the date it’s published but please don’t rely on it as legal advice. If you’d like to speak to us about your own legal requirements, please contact one of our expert lawyers.

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