(2) what steps have been taken to prevent data made available to organisations through the secondary users service giving an unfair advantage in bidding procedures;
(3) whether patients will be able to opt out of having their data used in limited data sets in the secondary users service.
There are no plans for the secondary users service (SUS) to provide data on a commercial basis. The current proposals for pseudonymised data extracts from the SUS will be available for any supplier who agrees the terms and conditions. Information from the SUS is used for commissioning purposes, and it is therefore not expected that patients would be able to opt out.
NHS Connecting for Health cannot comment on the specific monitoring process that each Caldicott Guardian within the NHS will employ. However, alerts where there is any potential irregular access will be sent to Caldicott Guardians. There are audit trails of any access to the NHS Care Record Service records which can be made available to Caldicott Guardians.
There are a number of mechanisms available to monitor access to the NHS Care Record Service. These mechanisms include:
network based intrusion detection and prevention;
network based access controls, audit and alerting;
user authentication recording and monitoring;
system level security audit trails;
application level security audit trails;
security audit trail reports; and
alerts to the Caldicott Guardian on specific accesses that may indicate unjustified access.
These technology mechanisms are dependent on Caldicott Guardians and Information Governance staff carrying out their roles and responsibilities in conjunction with the policies and processes that national health service organisations are required to adhere to. NHS Connecting for Health has regular communications with the NHS to gain feedback and discuss the various mechanisms for monitoring access provided by the NHS Care Record Service.