University Hospitals of Morecambe Bay, Digital Solutions
University Hospitals of Morecambe Bay, Digital Solutions
The Information Sharing Gateway
Briefly describe the initiative/ project/service; please include your aims and objectives
The Information Sharing Gateway (ISG), led by The Digital Solutions Team at University Hospitals of Morecambe Bay NHS Foundation Trust (UHMBT), are embarking on a new exciting development in collaboration with their public sector partners across the newly formed ISG User Community to develop Data Protection Impact Assessment (DPIA) functionality within the ISG. This collaborative development, which hopes to be available for use by Spring 2021, has been enthusiastically designed and developed with the help and support of its users. It looks to further build upon the benefits organisations already access through their use of the Information Sharing Gateway.
The Information Sharing Gateway (ISG) is a business enabling digital platform on which organisations can record information sharing agreements between departments and partner organisations. A public sector, not for profit project, which has seen exponential growth over the last 3 years, is now being used nationally by over 5,906 users in 3,310 public sector organisations to date. Over the last 2 years, system use has grown by nearly 70% with many organisations adopting the use of the system with region wide contracts to support the IG components of their work. Over the last 2 years, and since the introduction of GDPR, the project team and key stakeholders have remained focused to ensure the functionality of the system remains relevant and continues to support robust IG processes. Though the ISG User Community, there has been a huge demand to include additional functionality within the system to undertake Data Protection Impact Assessment (DPIAs) which have been an ongoing roadmap item since the introduction of GDPR.
Under the Data Protection Act 2018 (which implements GDPR), the concept of ‘privacy by design and default’, and as such ‘data protection impact assessments’ (DPIAs), are now seen as a mandatory function for all organisations. This means that data protection must be embedded into all activities, processes, projects and systems etc. from the design phase and throughout its lifecycle. DPIAs are an essential part of an organisation’s accountability obligations. Conducting a DPIA is a legal requirement for any type of processing. The ICO states ‘Under GDPR, failure to carry out a DPIA when required may leave you open to enforcement action, including a fine of up to €10 million, or 2% global annual turnover if higher.’
As all staff involved in designing projects are now accountable under GDPR, it’s imperative that they adopt a ‘data protection by design’ approach. Digital tools to support this work will help empower and support staff with the process and guide them through what is often a complicated and challenging area of work. The development will consist of an additional area/module within the existing functionality of the ISG where IG and non-IG professionals can undertake a standardised digital approach to a DPIA. This would include the ability to complete screening, collaborate on detail, assign and allocate tasks to other users to enable consultation, generate a risk assessment, review and provide easy access to DPIAs for internal and external auditing purposes. The information collected for a DPIA will then feed though relevant information to form the basis of a data sharing agreement, so providing further efficiencies.
– Supports remote working
– Within the ISG – Same registration
– Supports ‘Data Protection by Design’ principles
– Additional bolt on functionality to existing contracts (made available through ISG config)
– Supports a collaborative approach with the ability to assign certain tasks to certain roles within the system
– Standardised approach
– Supports the creation of a full Risk Assessment for activities
– Integrates into Data Sharing Agreements to form an end-to-end data sharing picture with associated risks
– Clear concise process– easy to use for non-IG professionals
What are the key achievements?
A key feature of the ISG is accessibility and as a web-based system, users are able to have access from any device, at any location to manage, review and sign off sharing agreements instantly. Having electronic sign off has given ISG users the ability to get sharing in place quickly, with the system proving indispensable for organisations when partaking in sharing activities for Covid-19 purposes over the last 9 months. 20/21 will see the system become truly sustainable, which has been a key achievement and not an easy task as a not for profit run project. With the help and continued support of its partner organisations, it hopes to continue to expand its functionality and develop further with an ambitious and exciting roadmap which includes DPIA functionality as a start. The Information Sharing Gateway (ISG) provides a simple answer to a big challenge for organisations trying to overcome information governance requirements when sharing information. The ISG is now being used by NHS, Local Authorities, Police, Schools and many other organisations across the UK. Over the last 12 months they have also connected with interested parties from Wales and Northern Ireland. The ISG has been a key enabler for several high profile regional and national projects including the work with LHCR.
Here are some of the regions currently contracting to use the system;
– Yorkshire and Humber
– NHS England – Midlands (11 STPs)
– East of England (3 STPs)
– Greater London Authority (18 London Boroughs)
– Lancashire & Cumbria – (Region wide coverage)
– North East Connected Health Cities & NECs (Region wide coverage)
– Cheshire and Merseyside (Region wide coverage)
– Greater Manchester (Region wide coverage)
– South East of England – (Limited coverage)
– South West of England – (Limited coverage)
– Kent & Medway – (Region wide coverage)
The ISG User Community, which started half way through 2020, has also proved a huge success and continues to showcase public sector innovation and collaboration at its very best. Cost savings, increases in efficiency and productivity. Public sector savings, calculated by an average cost saving, have demonstrated that in the 3607 current live data sharing agreements, a cost saving of £11,049,900.22 has been made nationally through the use of ISG Data Sharing functionality and tools since 2015. This translates to 10,117,635 working days. As ISG users create sharing agreements to a standardised and inclusive template, the creation and review process is reported now as being 500% more efficient for collaborators and owners. Signing off a sharing agreement has been estimated to be 1667% more efficient with the ISG As of January 2021, 5904 registered users, in 3309 Organisations are using the ISG to manage 3607 sharing agreements In 2020, the ISG’s licensed model was invested in by: LHCRE, NHS England, NHS Improvement, Health Education England, Cheshire and Merseyside Health and Care Partnership, Greater Manchester Combined Authority, Greater London Authority to name a few.
What are the key learning points?
What we learned and shared, as a not for profit project, is that it is important to remain open about your business model and ask for support and help for your partners to remain a success. 2020 provided an opportunity to review the success of the system to date and to look to connect with our users at a difficult time, to truly understand and find out where growth in functionality was needed to support them with their ever changing needs. We shared, we listened, we created. We gave the ISG User Community a place to come together to share ideas, create launch plans, discuss best practice and to get involved.
By connecting with organisations on large deployments, the ISG has offered economy of scale and we were able to build a portfolio of support to help further engage and enhance usage. We held virtual sessions on how to get the most from the ISG’s functionality and reporting features. We reviewed usage and created scripts to bulk register organisations, to further support large launches giving immediate access and quicker deployments when time was of the essence. There have been difficulties at times in accessing resource to develop the system. Accessing development resource outside of major cities, especially within the public sector, can be difficult as costs for good developer resource are not always fully understood. This year we have been fortunate to have the support of an excellent external consultant and a talented full-time developer both committed to UHMB. Communication, openness to great ideas, a great team and surrounding a project with good, supportive people has been key.
“Peter Wilson Greater Manchester Combined Authority The ISG is a key part of the GMCA strategy. It answers all the issues we had in relation to data sharing. The ISG is very straight forward and way to use and allows all agencies access, making it much easier than emailing round documents and having multiple responses.” ”Trust” is an important factor in information sharing and this starts with the assurance level of each organisation that we want to share information with.