NHS England has published an agreed model with GPC England for data sharing and data processing for PCNs, available on the NHS England GP contracts page – click here. I also attached both documents to this email. Although the use of these models is not mandatory and NCPs remain free to complete different forms of data sharing and data processing, their objective is to help NCPs develop their data exchange and processing activities for the provision of extensive service-based services under the network contract. The BMA`s guidelines on this matter will be available soon. With a team of more than 200 lawyers and national coverage, we are one of the leading companies that legally advise and support the NHS and independent health organizations. We act for more than 100 NHS bodies and we are on all national framework agreements – NHS SBS, NHS CPC, HealthTrust Europe, NHS Resolution, NHS Commercial Alliance and CSC. As part of the Primary Care Network Documentation Series (“NCP”), NHS England and GPC England have now published a data-sharing contract (“Agreement”) and related instructions: you can view the instructions here. These documents are models for facilitating discussions within a primary care network regarding data sharing and data processing to facilitate the provision of the De Direct Enhanced Network Contract service. The models were agreed by NHS England and GPC England. The agreement is only a proposal and not mandatory. Unfortunately, one size doesn`t suit everyone when it comes to PCN settings. While it is useful to have a model document so that NCPs do not have to develop their own contract, as outlined in the guide, the model does not replace legal advice.
There are some legal issues that NCP members must address before concluding and signing their data exchange agreement, including: The new primary care network agreement for NCPs stipulates that there must be an agreement on the exchange of data between member firms and all other organizations with which members` practices wish to share patient data. An agreement on model sharing is promised, but it is still expected. In the meantime, the clock is ticking around June 30 for registration. If the model is used, it must be developed among members of the Primary Care Network. Notes are provided at the end of the model. The use of this model is not mandatory. Primary Care Networks is free to close, at its sole discretion, different forms of data sharing and data processing. If the model is used, it must be developed among members of the Primary Care Network. Notes are provided at the end of the model. Here are some tips to prepare for the arrival of the model sharing agreement so that you can meet the June 30 deadline with your data sharing agreements: If your PCN uses a data processor (a computer/software company) to enable data sharing, who is responsible for managing the contractor? Who owns the contract and meets the requirements of the RGPD? Have you been diligent with respect to the contractor (and all subcontractors) required by the data protection rules? The Crown`s commercial services have issued a useful memo containing standard contractual clauses for data processing contracts, see Appendix A.
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