Product description

North West London Integrated Care Board (NWL ICB) use this Product to monitor the discharge status of patients across the trusts and local authorities in the area. This allows the ICB to fulfil its responsibility to support the timely and safe discharge of patients.

The Product enables the ICB Discharge Teams to access the appropriate information in a timely manner and from a single system, providing a safe and manageable solution allowing the ICB to deliver its direct care responsibilities. This information is only accessible in identifiable form by staff members who require this for their job role.

What are the purposes for processing my personal data in this Product?

This Product processes personal information (called ‘personal data’ under data protection laws) about you as a patient, when receiving care as an inpatient within hospital and then when discharged within the local areas being supported by local authorities. This is to ensure that patients are being discharged appropriately and receiving care in the most effective and timely way. This includes information about your health, medical condition and the speciality/ward which is currently supporting you or has previously supported you. The Product enables your care team in the hospital to deliver your treatment and continued care more effectively.

The use of the Product by the NWL ICB will improve the delivery of care and ensure that the discharge pathway you are on is appropriate and safe through better use of the information that the ICB and Trust hold supporting your care. This will include bringing together all required information about your treatment into one place to support your care.

The Product enables NWL ICB to identify the discharge pathways and plans in place including actions the ICB discharge teams can take to improve your care pathway. The ICB will use this Product to ensure you are provided with the best care and discharge within the most appropriate timeframe. This will also help Trusts and Local Authorities to improve the treatment provided and the discharge pathway.

What personal data about me is processed in this Product?

Personal data which directly identifies you (we call this directly identifiable data) will be processed by the ICB about patients who are having planned treatment scheduled, for the purposes above. Data that is processed by hospitals that use this Product may include your:

• name
• address including post code
• date of birth and age
• gender and sex
• NHS number and hospital record number
• living habits
• health information, including information about your medical condition, symptoms, diagnosis and treatment

Personal data about members of staff involved in the delivery of care may also be processed when using this Product, including the names of staff involved in providing care, their email address, their role/profession and planned absence information, so that your treatment can be scheduled.

Who is my personal data shared with?

Your personal data is accessed and used by the members of staff involved in your care in the ICB who are providing you with individual care and treatment, and support staff who need to help health care professionals to administer your care journey.

There will be anonymised data that will be shared with senior members of staff within NWL ICB and Local Authorities within North West London to allow the monitoring and improve the discharge pathways across North West London. This will allow these organisations to ensure that appropriate actions are taken to prevent delays and ensure the discharge procedures in place are being followed.

Your personal data will not be shared with any other organisations as part of this Product.

UK GDPR Information

Controllers of your personal data

Under data protection law the ICB using the Product is the legal controller of your personal data under data protection laws. The specific ICBs using the Product are listed on the Product Description page of the NHS England website.

Legal grounds for processing your personal data

The processing of personal data by ICB for the purposes explained above is permitted under the following legal grounds under data protection law (this is UK GDPR and the Data Protection Act 2018 (DPA 2018)):

• Public Task – Article 6(1)(e) of UK GDPR ‘necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.
• Health Care – Article 9(2)(h) of UK GDPR ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…” In addition, the legal grounds under paragraph 2 of Part 1 of the DPA 2018 apply (health care purposes).

The personal data processed about patients by the ICB for the purposes above is also confidential data. As the ICB is processing your confidential data to provide you with individual care, it is relying on your implied consent to do this, as you would reasonably expect the hospital to process your personal information this way to provide you with care. The ICB will keep your personal data confidential and only use and share it with other members of the care team to provide you with care, where you would reasonably expect them to, and subject to strict confidentiality controls to ensure your information remains confidential.

Processor acting on behalf of the ICB

The data platform contractor, Palantir Technologies UK Ltd is a processor acting on behalf of the ICB who are using this Product. They provide the data platform and the technology that the Product uses and only act on the instructions of the ICB.

Your rights under UK GDPR

You have the following rights under UK GDPR in relation to the processing of your personal data by the ICB for the purposes above:

• right to be informed
• right of access
• right to rectify
• right to object

Further information about these rights is in the NHS Federated Data Platform Privacy Notice. The ICB will also have a Privacy Notice on its own website which will explain more about how the ICB processes your personal data, your rights and how to exercise them.

Access contact details for data protection officers in the ICB using this Product.

Does the National Data Opt Out or any other opt out apply to this Product?

The National Data Opt Out and Type 1 Opt Outs do not apply to the processing of your personal data by the NWL ICB for the purposes explained above. This is because the ICB is processing your personal data to provide you with individual care and treatment and these opt-outs don’t apply in these circumstances.

More information

For more information about how personal data is processed within the Federated Data Platform please see the NHS Federated Data Platform Privacy Notice.