What is an NHS CRS Information Governance alert?

Information Governance alerts are automatically generated by the NHS Care Record Service, in response to certain types of actions (see 1.4) by NHS CRS users, which might point to a possible breach of patient confidentiality.

All alerts are reviewed to protect confidentiality and promote public confidence in the NHS CRS and NHS record-keeping.

Information Governance Alerts (IG Alerts for short) are distinct from other types of alert or warning that may occur in NHS CRS systems, as they are specifically about detecting possible misuse of patient records.

Specifically, IG Alerts are generated when an NHS CRS user:

• a) claims a legitimate relationship with a patient (self-claiming);
• b) overrides a patient's dissent to NHS CRS information sharing and accesses sensitive personal data about the patient that is maintained by another legal organisation;
• c) accesses sensitive personal data about the patient that is maintained by another legal organisation, where the patient has permitted that NHS CRS user to access their record from elsewhere;
• d) accesses information that has been 'sealed' at the patient's request (unless the user or their workgroup created the seal or the sealed information);
• e) attempts to access address information within a patient's record that has been flagged as sensitive on the Personal Demographics Service (this would always be unsuccessful as the address is protected).

Who monitors these IG alerts?

These alerts are received by specialist staff within the user's organisation who are responsible for managing privacy and confidentiality issues within the organisation.

They may be Caldicott Guardians, who are senior clinicians responsible for confidentiality issues, or Privacy Officers who will have a range of responsibilities overseeing privacy and security in their organisation. We shall use the term 'Privacy Officer' for either of these roles.

What happens to the IG alerts?

The Privacy Officer will review each IG alert to check that patient concerned was under the care of the organisation and the user's unit at the time the alert was raised, or in the case of (d) above, that there was a similarly named individual requiring treatment.

The Privacy Officer will also check that explanations given for the access to a patient's record are reasonable.

Should a particular user generate more than expected numbers of alerts for their role and responsibility, then further investigations would be made to determine why this was the case and whether there may be any misuse of systems.

Where an access may be made with a patient's permission (eg accessing a record where a patient has dissented-to-share or accessing sealed information), then it would not be possible for the Privacy Officer to check that the patient did indeed give permission.