A. It was identified for a number of one-off costs pharmacy contractors are facing, including information governance. Q. The new standard builds on the work and learning from 2018-19. A. To support the efficiency of future orders, ‘made to measure’ hosiery manufacturers may ask for a patient identifier when the order is placed, for example so that the template produced for that individual patient can be re-used in future. We aim for the Data Security and Protection Toolkit to be usable without reference to detailed … The final deadline for completing the mandatory questions was re-scheduled from March 31st 2020 to September 30th 2020. Do I need to have a confidentiality clause in the contracts of third party contractors who don’t have access to patient identifiable information? Before disclosing patient data, pharmacists would need to satisfy themselves that the person requesting the data is properly authorised under the Misuse of Drugs Act and that the request for information is consistent with the carrying out of routine checks. These assurances are provided through completion of an online assessment tool, the NHS Information Governance Toolkit (IGT). USB sticks and CDs/DVDs), ‘Level 3’ can be recorded but the pharmacy should insert a comment in the text field that states the requirement is not applicable, and that their policy is that they have no mobile computing devices. Two identical pharmacies holding the same information, computers and stock may have quite different physical security needs if one is located in an area of high crime and the other in a low crime area. This requires that personal data (which may be sensitive) such as patient identifiable information is not shared without patient consent or is otherwise allowed by law. This survey has been developed by NHS Digital to assist organisations in understanding the data security awareness of its staff. Q. I run a wholly mail order business. The Information Commissioner’s Office (ICO) enforces and oversees data protection legislation. e-Learning – data security awareness – level one (v3.0), 3. Where is the funding for pharmacies initially implementing the IG requirements coming from? A. If the pharmacy does not use any mobile computing devices i.e. Q. Pharmacies should use their judgement based on local circumstances on which pieces of hardware should be recorded on the asset register. In the terms of the contract which the NHS England Area team has negotiated with the waste contractor, provision should have been made to safeguard confidential information. Occasionally a pharmacy may be visited by a police officer who is undertaking an investigation into an alleged serious criminal offence (i.e. A. We would recommend taking expert advice from your system supplier. Find out the latest on pharmacy funding and NHS statistics. The impact of that loss is likely to be moderate (small number of patients affected) therefore the risk is low. The Data Security and Protection Toolkit is an online self-assessment tool that allows organisations to measure their performance against the National Data Guardian’s 10 data security standards. A. Whilst there is not a specific requirement in data protection legislation to encrypt computers containing personal information, contractors must ensure that personal information is adequately protected. A. There are no mandatory requirements for how the information asset register should be structured but it should include information on information stored (e.g. These guides take you through the definitions used in the standards, what the standards are asking of you, suggestions and examples of how this might be achieved, how this relates to common current practices, and useful resources. A. Q. Use our form to help you answer 12 questions. Personal data (which may be sensitive) includes patient information e.g. Q. I currently donât use any mobile computing systems in my pharmacy. Queries on specific IG requirements can be found towards the bottom of the page. Q. I have already submitted my baseline IG Assessment. If the device has patient information on it, it must be protected. The DSP Toolkit Compliance Service is a bespoke consultancy service that delivers a detailed review of your organisation’s data protection regime, recommended corrective actions for achieving full compliance with the 2019–20 DSPT standard, updates to any necessary documentation, support and guidance to improve your security … If so, only the minimum amount of personal data necessary should be disclosed. Q. Return to the section: Data security and information governance, Return to the section: Data Security and Protection Toolkit, Return to the Pharmacy IT hub or IT a-z index. Q. An alternative to the patient’s name could be using the patient’s PMR record number which can be traced back to the patient by the pharmacy or alternatively a unique identification number provided by the manufacturer that the pharmacy can record on the patient’s PMR record for future reference. As part of the 2009/10 community pharmacy contractual framework funding settlement, the Department of Health and Social Care (DHSC) agreed to make provisions against the excess margin available to contractors as established by the Margins inquiry (ie money already with contractors) over the £500 million agreed as part of the CPCF funding. Guidance on reporting an incident for GDPR and NIS. A locum may be able to fulfil this role, but this will be for local decision. For example the data transfer SOP includes suggested procedures linked to different data transfer methods â if a pharmacy uses a method of transferring information which isnât covered by the template SOP; the contractor would have to add information on this particular data transfer method into the SOP. This page provides copies of historic guidance and training for reference purposes. As with the Information Governance funding, this was paid out through the general funding arrangements rather than via a specific fee. If there are flows outside of the UK, it is important to undertake an appropriate risk assessment and put in place mitigating controls, for example contractual requirements on the supplier. 'Key roles and the DPO' provides a guide for social care providers to the organisational roles involved in completing the Data Security and Protection Toolkit. There are no templates for this requirement â it is sufficient to document that the checks have been undertaken e.g. The DSP (Data Security and Protection) Toolkit is an online data security self-assessment. If a decision is made to disclose without consent, an accurate record must be made of: who the request came from, the reasons for releasing the data without consent, whether you attempted to obtain patient consent, and if not why not, why patient consent was refused and what information was disclosed. A. Please ensure your email address is correct. General guidance from Public Health Englandâs âAccess to supervised doses of opioid substitution for people in police custody adviceâ available here may be useful. Patient identifiable information should not be shared without patient consent. It is important to make some comments to support your score, this could be by making some comments in the comments box or ticking the relevant evidence obtained boxes but it is not mandatory to complete the optional fields to record where each piece of evidence is located or to upload evidence such as policies and procedures. A. Can a self-employed locum pharmacist be the IG lead for a pharmacy? Data Security and Protection Toolkit staff awareness questions. This page includes guidance carried over from the predecessor system, the 'Information Governance Toolkit'. The Data Security and Protection Toolkit uses cookies to improve your on-site experience. Q. A. The concept behind having an information asset register is identifying all relevant hardware, software and information to ensure it can be appropriately protected. A key consideration is whether there are any other sources of this data. Q. Iâm currently in the process of data mapping and risk assessing all flows of personal information. Does this mean that I need to provide the manufacturer with the name of the patient? No technical knowledge is needed. Data Security and Protection Toolkit on a spreadsheet, 6.2. Data security standards - big picture guides. For example, a pharmacy may find it helpful to include a sticker on the asset with an assigned asset reference number. It is recognised however that this may take some time to achieve. The pharmacy must be able to show that the role has been appropriately assigned. Do I need to also maintain this information in a separate Information Asset Register? If a pharmacy has missed the 31st March deadline, we would recommend contacting your local NHS England team to discuss this. Data security standards - big picture guides, 6.1. Therefore, as an interim measure, if following a risk assessment it is felt that continued reliance upon unencrypted data is necessary for the benefit of patients, the outcome of the risk assessment must be reported to the most senior person in the organisation, so that he/she is appropriately accountable for the decision to accept data vulnerability or to curtail working practices in the interests of data security.â Therefore encryption had not been mandatory to achieve Level 2 compliance with the NHS IG requirements as outlined in the older version 9 of the IG Toolkit (now replaced by DSPTK). To register for the IG Toolkit, I need to provide my email address. More information about âprivacy noticesâ can be found on the Information Commissionerâs website. A. How can this be achieved? PSNC does not believe that this is appropriate as an ongoing measure in managing supply. The NHS requirements relate only to protecting patient identifiable information therefore Requirement 116 relates only to the contracts of contractors who have access to patient identifiable information, for example PMR suppliers. Further guidance on the powers of authorised persons under the Misuse of Drugs legislation may be available from the Home Office, the Association of Police Controlled Drugs Liaison Officers, the General Pharmaceutical Council, the NPA (for members) and from the RPS (for members). COVID-19 update: It has been agreed that no action will be taken against contractors who have not completed the Data Security and Protection toolkit for 2019/20, provided they are working to complete the toolkit … On the Information Governance Toolkit, there are fields linked to each requirement to record the location of evidence or to upload evidence. The Toolkit isn’t ‘locked’ at midnight on the 31st March therefore it may be technically possible to still make a submission after the deadline. Will funding be available in future years to reflect the ongoing costs in continuing to comply with the requirements? These guides for social care take you through the definitions used in the standards, what the standards are asking of you, suggestions and examples of how this might be achieved, how this relates to common current practises, and useful resources. ; … Toolkit completion: Overview: Five steps for completing the Data Security and Protection Toolkit 2019/20– this gives a step-by-step guide to completing the Toolkit and references other materials. What do these refer to? General Practice however there may be alternative questions relevant to just your organisation type: Data Security and Protection Toolkit – Administrator Guide v 1.5 FINAL 03/07/2019 ... Data Security and Protection Toolkit … A. To update details users need to log-in and then select the ‘Organisation Profile’. Q. I canât obtain a common branded product from my wholesaler. This includes things like putting in place appropriate policies and procedures, undertaking risk assessments and putting in place appropriate mitigation to safeguard data and having good governance/audit arrangements to prevent contraventions of data protection regulations. Q. I recently ordered some âmade to measureâ hosiery but the manufacturer has requested the patientâs details as part of the ordering process. A. As part of requirements, you need to consider if information about patients is being transferred outside of the UK (e.g. Q. Responses to frequently asked questions regarding the Data Security and Protection Toolkit. Historic Data Security and Protection Toolkit guidance and training, 7.1 Guidance carried over from the IG Toolkit, 9.1 e-Learning – data security awareness – frequently asked questions. For example if a contractor owns multiple pharmacies, he may feel it appropriate to appoint one central lead with local leads in each store to provide information on local circumstances and support pharmacy implementation of the requirements. We also have video guides with advice on how to complete each question. PSNC is currently in discussion with the DHSC to finalise the funding allocation for business continuity planning. The 'Data Security Meta Standards' document gives the bigger picture of where the standards fit in. When submitting the Online Toolkit Assessment, if you get interrupted and have to exit the Toolkit, is the data saved so you can come back and finish the assessment at a later date? This outlines the entry level Data Security and Protection Toolkit evidence items. User-friendly, this guide makes completing the updated Toolkit … Q. When patients return waste medicines, I currently put these in my controlled waste (DOOP) bin, complete with labels. Q. I currently maintain a comprehensive list of the hardware and software I own for insurance purposes. Both are linked to the same premises. Further our recent news story Contractor Notice: Drug Tariff to go fully paperless from April 2021,  NHS Business Services Authority... PSNC and the British Medical Association (BMA) have today issued a statement on medicines supply ahead of the end of... âWe Are Undefeatableâ is an award-winning campaign and movement supporting people with a range of long term health conditions, developed... Today PSNC hosted the Community Pharmacy Brexit Forum hearing updates from a number of organisations, including NHS England and NHS... PSNC Toolkit completion: Overview: Five steps for completing the Data Security and Protection Toolkit 2019/20– this gives a step-by-step guide to completing the Toolkit and references other materials. If a pharmacy has not notified the ICO, this would be a breach of data protection legislation and a criminal offence. The ICO has published guidance on what they consider to be ‘reasonable steps’. For many of the questions, I donât have the specific physical security controls in place however I am in an area of low crime. Q. Therefore, before faxing a prescription to a manufacturer, any information that could be used to identify the patient must be obscured / redacted in black ink unless the patient has consented to their personal data being disclosed. Q. Information Governance ensures necessary safeguards for, and appropriate use of, patient and personal information. Q. I have had a call from a local police station. 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