Name of Product

Antimicrobial resistance (AMR) Aggregated Data Dashboard– Pseudonymised / De- identified Data.

Broad Description of Product

This Product produces dashboards on:

• hospital admission trends for patients with a bacterial infection and/or sepsis,
• prescribing trends in primary care, and
• patients prescribed multiple antibiotics.

This is part of the NHS England’s Antimicrobial Resistance (AMR) Programme. The key objectives of the Product are to:

• Provide a tool to enable monitoring of antimicrobial resistance at local, regional, and national level to benchmark and inform strategy development as the NHS continues to recover from the Covid 19 pandemic.
• Provide a tool to enable clinicians and pharmacists (primarily these are pharmacists in antimicrobial stewardship roles in NHS Trusts and Integrated Care Boards) to view population health data in order to understand and improve outcomes as the NHS continues to deal with the recovery from the Covid 19 pandemic.
• Provide a means of linking data to support evaluation and operational improvement, to better understand the causes of infection and optimal management across the NHS.

Use Case

Population Health Management

Controllers who use this Product

NHS England is the Controller for this Product.

The purpose for processing your personal data

The purpose of the NHS England Antimicrobial Resistance (AMR) programme which has created this Product is to work collaboratively to deliver on the following ambitions set out in the UK Government’s 5 Year UK Antimicrobial Resistance (AMR) National Action Plan (NAP):

• halve the number of healthcare-associated Gram-negative Bloodstream Infections, delivering a 25% reduction by 2021-2022 and the full 50% by 2023-2024
• reduce the number of specific drug-resistant infections in people by 10% by 2025
• reduce UK antimicrobial use in humans by 15% by 2024
• reduce community antimicrobial use by 25% by 2024.

The purpose of the dashboards in this Product is to enable analysis of antimicrobial resistance and infection management patterns across patient pathways, across multiple organisations and at different organisational levels via the dashboards.

The dashboards are produced by NHS England in the National Instance of FDP using De-Identified Data. The data in the dashboards which is shared with other organisations is Anonymous Aggregated Data.

The dashboards enable:

• authorised users to explore hospital admission trends for patients with a bacterial infection and/or sepsis,
• prescribing trends in primary care, and
• analysis of patients prescribed multiple antibiotics in a 12-month period.

The dashboards will support the optimisation of surveillance of community and healthcare associated infections and monitoring the impact of fewer prescriptions for antimicrobials.

Further information about NHS England’s Long Term Plan for Anti-microbial resistance (AMR) can be found here – NHS England » Antimicrobial resistance (AMR).

Type of Data Processed & categories of data

Personal Data – De-Identified Data

De-Identified Data will be processed for the purposes of producing the dashboards. Personal Data is de-identified by NHS England before it is transferred into FDP for use in the Product.

Data that is processed by this Product includes De-Identified Data about an individual’s:

• age
• sex
• health information about infections, including information about an individual’s diagnosis, treatment, medication, and outcome, including mortality information where applicable
• ethnicity

Legal grounds for processing personal data in FDP and sharing it (if applicable)

The processing of De-Identified Data by the Controller for the purposes identified above is permitted under the following legal grounds:

UK GDPR

• Legal Obligation – Article 6(1)(c)… ‘the processing is necessary for compliance with a legal obligation’. This applies where NHS England is directed under section 254 of the Health and Social Care Act 2012 to collect and analyse personal data for the purpose of producing the dashboards;
• Substantial Public Interest – Article 9(2)(g) ‘processing is necessary for reasons of substantial public interest’ together with the legal ground in Schedule 1, Part 2, Paragraph 6 of the Data Protection Act 2018 (“DPA 2018”) “statutory etc and government purposes”. This applies where NHS England processes personal data under Legal Obligation or Public Task above;

Confidential Data

NHS England is required by law to process the De-Identified Data it collects and analyses in the Product to produce the dashboards. This is required under legal directions issued by the Secretary of State for Health and Social Care to NHS England under section 254 of the Health and Social Care 2012 Act (Legal Direction).

The data which is shared with users through the dashboards is Anonymous Aggregated Data which is not Confidential Data.

Who is Processing your Personal Data as Processor on behalf of the Controller

The Data Platform Contractor, Palantir Technologies UK, LTD is a Processor for this Product.

No Personal Data is being processed by the PET Contractor IQVIA LTD, who is not a Processor for this Product.

Who your data is shared with

Anonymous Aggregated Data is shared with a range of dashboard users. The data shared does not therefore identify anyone.

Users of the dashboards may include:

• NHS England national and regional AMR stakeholders
• UK Health Security Agency (UKHSA) National and Regional AMR stakeholders
• Department for Health and Social Care
• NHS Business Services Authority (NHS BSA),
• National Institute for Health and Care Excellence
• Commissioning Support Units supporting on work related to AMR
• Local Authorities
• Integrated Care Boards (ICBs)
• Public Health Collaboratives
• NHS Trusts
• Place-based partnerships
• Primary Care Networks (PCNs)
• Academic Health Science Networks (AHSNs)

Your rights under UK GDPR

The following rights under UK GDPR apply to the processing of your Personal Data in the dashboards for the purposes above:

• Right to be informed
• Right of access
• Right to rectify

Further information about these rights is in the FDP Privacy Notice here.

If you wish to exercise your rights you should contact the NHS England Data Protection Officer at england.dpo@nhs.net.

Do any Opt Outs apply to this Product?

No Opt Outs apply to this Product.

• Type 1 Opt Outs do not apply because the datasets used to create the dashboards do not contain confidential patient information that has been collected by NHS England from GP Practices.
• National Data Opt Outs do not apply because:
  • the collection and analysis of data by NHS England to create the dashboards has been carried out under a legal obligation (the Legal Direction) and therefore the National Data Opt Out does not apply.
  • the data which is shared with other organisations through the dashboards is not confidential patient information as it is Anonymous Aggregated Data and therefore the National Data Opt Out does not apply.