General Practice Extraction Service (GPES)

Transcription

1 General Practice Extraction Service (GPES) Customer: Health and Social Care Information Centre (HSCIC) Requirement: Patient Objections Management (POM) Customer Requirement Reference Number: NIC V5Z0L Date: February 2014 Version 1.0 GPES reference: NIC V5Z0L Page 1 of 23

2 Contents 1. Executive summary Customer overview Strategic business case Information requirements HSCIC information transformation plan Data management Data delivery Data quality Certification Appendix A Acronyms Appendix B Definitions Appendix C Read codes Appendix D Recording objection codes Appendix E GPES data extraction and delivery GPES reference: NIC V5Z0L Page 2 of 23

3 1. Executive summary 1.1 Overview The NHS Constitution 1 states You have the right to request that your confidential information is not used beyond your own care and treatment and to have your objections considered. In December 2013, NHS England issued Directions to the Health and Social Care Information Centre (HSCIC) (under the Health and Social Care Act 2012) that included a Direction in relation to the management of patient objections: The HSCIC is directed by the Board pursuant to paragraph 3 of these Directions to put measures in place as part of the establishment and operation of the information systems which are the subject of these Directions to ensure that where any primary care data are coded to indicate a patient's objection to disclosure of their identifiable primary care data to the HSCIC or any third party, to the extent that the HSCIC is acting in pursuance of these Directions in relation to that patient the HSCIC will only collect non-identifiable primary care data and those data items necessary to enable the HSCIC to record the fact of the patient's objection and that the data items necessary to record the fact of the patient's objection shall be collected and stored separately from other information to be collected in order to prevent any possibility of identification or re-identification of the patient within the HSCIC. 2 The HSCIC is committed to supporting a patient s wishes in respect of sharing confidential information. The HSCIC Guide to confidentiality in health and social care 3 states that: Patients can object to information about them leaving a general practice in identifiable form for purposes other than direct care, then confidential information about them will not be shared. This is referred to throughout this documentation as a type 1 objection. Patients can object to information about them leaving the HSCIC in identifiable form, then confidential information about them will not be sent to anyone by the HSCIC. This is referred to throughout this documentation as a type 2 objection. This data extraction is to enable the HSCIC to identify patients who have recorded an objection, or the withdrawal of an objection in order to respect patients wishes 1 Department of Health, The NHS Constitution: the NHS belongs to us all. [Online] Available at: [Accessed 27 November 2013] 2 NHS England, The Health and Social Care Information Centre (Establishment of Information Systems for NHS Services: Collection and Analysis of Primary Care Data) Directions [Online] Available at: [Accessed 30 January 2014] 3 HSCIC, A Guide to Confidentiality in Health and Social Care [Online] Available at: [Accessed 25 November 2013] GPES reference: NIC V5Z0L Page 3 of 23

4 and monitor the levels of patient objections. Patients have the right to object to any extraction of patient identifiable data from their general practice record unless there is (a) a statutory duty to share information, (b) a court order or (c) an overriding public interest in disclosure. 1.2 Customer organisation and sponsor This requirement is for, and is sponsored by, the care.data Programme Director of the HSCIC. 1.3 What data are needed This requirement looks to extract patient level data about objection codes and a number of aggregate counts. This requirement will extract data about these objections, and the withdrawal of these objections. 1.4 Why the data are needed The data are needed for two purposes: 1. To respect the wishes of patients who have recorded a type 2 objection or the withdrawal of a type 2 objection. 2. To monitor the levels of patient objections. Where a type 2 objection is recorded then the HSCIC will use the NHS Number extracted to identify if there is a matching NHS Number within the data they hold. Where there is a matching NHS Number then the data to be released will be deidentified. This will ensure that no patient identifiable data that the HSCIC holds about that patient will be released for purposes other than direct care. If there is no match on the NHS Number, then it will not be possible to de-identify those data. Data are also needed to identify the number and trend of objections, and to ensure that the HSCIC applies the most recent type 2 objection code regarding the release of a patient s identifiable data from the HSCIC. 1.5 How often the data are needed There will be two extractions of data per month. 1.6 Data output files The HSCIC will receive one Customer Request Output (CRO) for each data extract. 1.7 Information Governance (IG) assessment The HSCIC Information Governance Assessment has assessed this requirement to be identifying (please refer to HSCIC IG Assessment NIC V5Z0L contained in this Independent Advisory Group (IAG) pack). GPES reference: NIC V5Z0L Page 4 of 23

5 2. Customer overview 2.1 Customer organisation The HSCIC was set up as an Executive Non Departmental Public Body (ENDPB) in April The Health and Social Care Act sets out the HSCIC s responsibilities, which include: Collecting, analysing and presenting national health and social care data. Setting up and managing national IT systems for transferring, collecting and analysing information. The HSCIC can be directed to do this by the Secretary of State or NHS England. Publishing a set of rules (called a Code of Practice) to set out how the personal confidential information of patients should be handled and managed by health and care staff and organisations. Building up a library of 'indicators' that can be used to measure the quality of health and care services provided to the public. Acting to reduce how much paperwork doctors, nurses and care workers have to complete by ensuring that only essential data are collected, and that the HSCIC avoids collecting the same information twice. Helping health and care organisations improve the quality of the data they collect and send to the HSCIC by setting standards and guidelines to help them assess how well they are doing. Creating a register of all the information that the HSCIC collects and produces, and publishing that information in a range of different formats so that it will be useful to as many people as possible, while safeguarding the personal confidential data of individuals. The HSCIC s statutory functions and duties are set out in Part 9, Chapter 2 of the Health and Social Care Act sections 252 to and in Schedule Requirement Framework Requirement frameworks exist for services in primary care eg Quality Outcomes Framework (QOF) and Enhanced Services. There is no applicable framework for this customer requirement. 4 HSCIC, Who we are and what we do: Our role [Online] Available at: [Accessed 25 November 2013] 5 Legisation.gov.uk, Health and Social Care Act 2012 [Online] Available at: [Accessed 25 November 2013] GPES reference: NIC V5Z0L Page 5 of 23

6 3. Strategic business case 3.1 What data are needed The purpose of this requirement is to respect patient wishes regarding objections to sharing their patient identifiable data. There are two types of objection codes that a patient can record on their general practice record. Type 1 objection code - a patient can object to information containing identifiable data about them from leaving their general practice for purposes other than direct care. Type 2 objection code - a patient can object to any information containing identifiable data about them from leaving the HSCIC for purposes other than direct care. See Appendix C for the Read codes for patient objections. Type 1 objection To prevent patient identifiable data leaving the general practice for secondary uses the patient must have the code Dissent from secondary use of general practitioner patient identifiable data recorded in their general practice record. If a patient changes their mind about objecting to their patient identifiable data leaving their general practice for purposes other than direct care then they can reverse the decision by recording the code Dissent withdrawn from secondary use of general practitioner patient identifiable data in their general practice record. Type 2 objection The type 2 objection code applies to information received by the HSCIC from all places patients receive NHS care, such as hospitals. If a patient objects, information that identifies the patient will only leave the HSCIC for purposes other than direct care in limited circumstances, where a researcher can demonstrate to the HSCIC that a patient has consented to their data flowing for a particular purpose or where the law requires its release such as public health emergencies. Where a patient has never had a type 2 objection or withdrawn objection code recorded in their general practice record, then this requirement will not extract any data for that patient. 3.2 Why the data are needed The data are required to support a number of activities, shown on the next page. GPES reference: NIC V5Z0L Page 6 of 23

7 1. Extracting data about objections to patient identifiable data leaving general practice for purposes other than direct care is required to establish if a trend of objections for each general practice exists. This is recommended by the Caldicott Information Governance Review Extracting data about patients objecting to their patient identifiable data leaving the HSCIC for purposes other than direct care is required to respect the wishes of patients and to enable the HSCIC to comply with the Directions issued by NHS England in relation to managing patient objections Aggregated data are required to count the number of patients at each general practice who have currently recorded a type 1 objection or a type 1 withdrawn objection. Then using a count of patients at each general practice, the proportion of patients currently objecting or withdrawing their objection at each general practice can be calculated. 4. Aggregated data are required to count the number of patients at each general practice who have currently recorded a type 2 objection or a type 2 withdrawn objection. Then using a count of patients at each general practice, the proportion of patients currently objecting at each general practice can be calculated. 3.3 How the data will be used by the customer Type 1 objections Where a patient records a type 1 objection, then the HSCIC will create a report containing an aggregate count of the number of patients at each general practice who have currently recorded a type 1 objection or a type 1 withdrawn objection. Type 2 objections Where a patient records a type 2 objection, then the HSCIC will prevent identifiable data about that patient being released for purposes other than direct care. Any teams within the HSCIC that may release data in an identifiable form will be responsible for ensuring they exclude the release of any identifiable data of patients who have objected, except in limited circumstances where the law requires its release or where a researcher can demonstrate to the HSCIC that a patient has consented to their data flowing for a particular purpose. The HSCIC will use the NHS Number extracted to identify if there is a matching NHS Number within the data they hold. Where there is a matching NHS Number then the data to be released will be de-identified. If there is no match on the NHS Number, 6 Department of Health, The Information Governance Review - Information: To Share or not to share? [Online] Available at: _accv2.pdf [Accessed 28 January 2014] 7 NHS England, The Health and Social Care Information Centre (Establishment of Information Systems for NHS Services: Collection and Analysis of Primary Care Data) Directions [Online] Available at: [Accessed 30 January 2014] GPES reference: NIC V5Z0L Page 7 of 23

8 then it will not be possible to de-identify those data. See Appendix D Recording Objection Codes. 3.4 Why GPES is the most appropriate service to extract this data There are three key reasons why GPES is the most appropriate service to deliver this requirement: 1. The requirement seeks to extract data from general practice systems, which GPES is specifically tailored to deliver. 2. GPES will provide a standardised framework for the extraction of primary care data. With the aid of general practice system suppliers, GPES will only extract data general practices use for operational and clinical purposes. Other than opting in to the data extraction, the data collection and extraction burden on general practices will be negligible. 3. This requirement is currently the only one of its type known to GPES, so there is no risk that GPES is duplicating any existing/live datasets. GPES reference: NIC V5Z0L Page 8 of 23

9 4. Information requirements 4.1 Patient level or aggregated data This requirement relates to the delivery of patient level and aggregate data. 4.2 Indicator set This requirement will extract data for patients that have recorded objections to sharing their data and are defined as registered, deceased, left the general practice or not registered for general medical services but are registered for another service, such as contraception or child health. Aggregate counts As part of this requirement a number of aggregate counts will be returned: The total number of patients at each general practice. The number of patients at each general practice who have currently recorded a type 1 objection. The number of patients at each general practice who have currently recorded a type 1 withdrawn objection. The number of patients at each general practice who have currently recorded a type 2 objection. The number of patients at each general practice who have currently recorded a type 2 withdrawn objection. Patient level data Where a patient objects to their patient identifiable data leaving the HSCIC then the patient must have the following code Dissent from disclosure of personal confidential data by Health and Social Care Information Centre recorded in their general practice record. If a patient changes their mind about objecting to their patient identifiable data leaving the HSCIC then they can reverse the decision by recording the code Dissent withdrawn from disclosure of personal confidential data by Health and Social Care Information Centre in their general practice record. Where a patient has objected or has withdrawn their objection to their patient identifiable data leaving the HSCIC, the following data items are required: GPES Data Item NHS Number General Practice ID Purpose This will be used by the HSCIC to identify if there is a matching NHS Number within any identifiable data they plan to disclose. This will be used to monitor which general practices are recording patient objection codes. GPES reference: NIC V5Z0L Page 9 of 23

10 Code The HSCIC requires the following objection codes: Dissent from disclosure of personal confidential data by Health and Social Care Information Centre; or Dissent withdrawn from disclosure of personal confidential data by Health and Social Care Information Centre. Recorded Date The date the objection code and/or withdrawal of objection code was recorded on a patient s general practice record. This requirement will extract a full history of type 2 objection codes so the HSCIC can ensure that the latest code is always applied and that patient wishes are respected. 4.3 Number of counts per indicator Not applicable for this requirement. 4.4 Key clinical domain Not applicable for this requirement. 4.5 General practice cohort This requirement will extract data from every general practice in England that participates in the Patient Objections Management customer requirement. 4.6 Small numbers Not applicable for this requirement. 4.7 Terminology systems This requirement will only extract data from general practice systems that use the Read version 2 (READ2) or the Clinical Terms Version 3 (CTV3) terminology systems. GPES reference: NIC V5Z0L Page 10 of 23

11 5. HSCIC information transformation plan 5.1 Data transformation process with the Data Provider Output (DPO) For this requirement, the HSCIC will not undertake any transformation on the Data Provider Output (DPO). GPES will use the General Practice Extraction Tool - Query (GPET-Q) system to collate the general practices DPOs into Customer Request Output (CRO) file and then send the resulting CRO file to the HSCIC Data Management Environment (DME). GPES reference: NIC V5Z0L Page 11 of 23

12 6. Data management 6.1 Data access and storage The data for this requirement will be stored in the HSCIC DME. Further details are available in Appendix E. The data stored in DME will be encrypted and have access controls restricting who has access to the data. Viewing access to the objection codes will be restricted to situations where it is necessary to investigate problems or to respond to general practice enquiries. 6.2 Data retention The data will be retained by the HSCIC for no longer than is necessary as required under the Data Protection Act Data sharing agreement The customer will abide by the terms of the agreement, and its information governance procedures and protocols. GPES reference: NIC V5Z0L Page 12 of 23

13 7. Data delivery 7.1 Number and format of Customer Request Output (CRO) file(s) There will be one CRO file which will contain data regarding objections from data leaving general practices for purposes other than direct care, and data regarding objections of data being released by the HSCIC for purposes other than direct care. 7.2 CRO file content and structure The table below provides an example of how the data will be returned in the CRO file: General practice code A0001 Reporting period start date 06/04/2014 Reporting period end date 19/04/2014 The total number of patients at a general practice 450 The number of patients at a general practice who have 25 currently recorded a type 1 objection The number of patients at a general practice who have 10 currently recorded a type 1 withdrawn objection The number of patients at a general practice who have 30 currently recorded a type 2 objection The number of patients at each general practice who have 15 currently recorded a type 2 withdrawn objection Practice Read code Date recorded NHS Number A0001 9Nu A0001 9Nu A0001 9Nu A0001 9Nu Data recipient and method of delivery Data will be transferred to HSCIC DME servers. The recipient will be the HSCIC. 7.4 Scheduled extraction date, delivery date and frequency There will be two extractions of data per month that will be run around the end of the first and third week of each month. Once the extract has been run, it will take around two to four weeks before the HSCIC can action the objection. The reporting period start date will remain the same for each extraction and will always be set as , which will examine patients full histories. The reporting period end date is a variable date and will generally be around the end of the first and third week of each month. This is an ongoing requirement and will continue to run until such time as it is deemed no longer necessary. GPES reference: NIC V5Z0L Page 13 of 23

14 7.5 CRO Summary Record Each one of the scheduled extractions is technically referred to as a Scheduled Query Instance (SQI). For each SQI, the recipients will receive a CRO Summary record, which will describe: The total number, and list of, general practices the SQI was scheduled at. The total number, and list of, general practices that have provided data within the CRO for the SQI. The total number, and list of, general practices that made a decision to decline participation for the SQI. The total number, and list of, general practices where no data or decision is available for the SQI. GPES reference: NIC V5Z0L Page 14 of 23

15 8. Data quality 8.1 General practice systems This requirement will only extract data from general practices clinical IT systems. Other systems maintained by general practices are out of scope. Under the GPES framework, only coded data are extracted. This reduces the need for general practice system suppliers or GPES to interpret free text data. In addition to the benefits that coded data provides, the GPES process also provides a data certification service. As part of data certification, GPES tests whether general practice system suppliers technical specifications are correctly defined, based on the Extraction Requirement that GPES distributes to general practices clinical systems suppliers. Although the points noted above reduce data quality risks, some will still be present. This is because the data extracts will only be as good as the data inputs. Due to data entry errors, GPES cannot control or govern the data collection process. Consequently, it needs to be noted that GPES cannot give assurances that the returned data fully meets the key data quality principles of: Accuracy that the data has been accurately captured, for instance, that a BMI score of 22.4 has not been inadvertently recorded in the general practice system as Completeness that every diagnosis, symptom, intervention and activity related to each patient is captured. There may be cases where patients do not access general practice services for each health related problem or that general practices only capture primary symptoms and diagnoses. It is therefore possible that the data in the CRO may be under reported. Timeliness that data related to all diagnoses, symptoms, interventions and activities, is captured in a timely manner (i.e. before the date of extraction). There may be cases where there is a time lag between an event occurring and the related data being recorded in the general practice system. 8.2 Expert HSCIC clinical opinion on the likely quality of the data output The Read codes for this requirement have been reviewed and agreed by a HSCIC National Clinical Lead. The Read codes that are to be extracted have been published as part of the care.data guidance and FAQs which NHS England, the BMA, HSCIC and the RCGP have worked collaboratively on. GPES reference: NIC V5Z0L Page 15 of 23

16 9. Certification 9.1 Feasibility testing Not applicable for this requirement. 9.2 Extraction requirement certification GPES offers three levels of certification standards against the Extraction Requirement - Gold, Silver and Bronze, with Gold being the most comprehensive. This requirement is to be certified against the Silver standard. See Appendix B Definitions for further details of certification levels The Extraction Requirement is circulated to general practice system suppliers and sets out the data that will need to flow to the HSCIC for this requirement. GPES reference: NIC V5Z0L Page 16 of 23

17 10. Appendix A Acronyms Purpose of appendix The purpose of this appendix is to set out the acronyms and abbreviations, with their corresponding terms, used in this document. Appendix content Acronym Definition CQRS Calculating Quality Reporting Service CRO Customer Requirement Output CTV3 Clinical Terms Version 3 DME Data Management Environment DPO Data Provider Output GMS General Medical Services GP General Practitioner GPES General Practice Extraction Service GPET-Q General Practice Extraction Tool - Query HSCIC Health and Social Care Information Centre IAG Independent Advisory Group IG Information Governance NHS National Health Service POM Patient Objections Management QOF Quality and Outcomes Framework READ2 Read Version 2 SQI Scheduled Query Instance XML Extensible Markup Language GPES reference: NIC V5Z0L Page 17 of 23

18 11. Appendix B Definitions Purpose of appendix The purpose of this appendix is to provide definitions for a selection of terms used in this document. The terms are included in this appendix because they are either technical in nature and, therefore, need a clear description or because they have a specific meaning within the context of this document. Appendix content Term Aggregated data / Aggregated count Certification Definition Data combined from several records containing totals rather than data attributable to an individual. The total is derived from patient level data that has been grouped (summarised). A process whereby a general practice system supplier s data extraction queries are tested against sample data to assess whether the query results match expected results. The certification process reduces the risk of data extraction errors. There are three different levels of Certification available within GPES: Gold: Certification of the Extraction and Post Extraction requirements against Test-pack data to produce predictable actual results against pre-determined expected results. The HSCIC/customer will provide Test-pack data for the certification processes and the HSCIC will support certification of customer systems that receive data from GPES. An example of this might be where a customer wants to make payments based on the extraction results and therefore this must support payment calculations to the penny, such as the Calculating Quality Reporting System (CQRS). Silver: Certification of the Extraction and Post Extraction requirements against Product Test data to produce realistic actual results. This can only be assessed against anecdotal estimation whilst reflecting the effectively anonymised data used in the certification. In other words, the extracted data is correct against the data set interrogated against but may not meet all test conditions. An example of this might be where a customer has other information, such as prevalence and therefore has a reasonable level of expectation of data to be returned. Bronze: Certification of the Extraction and Post Extraction requirements against Product Test data to produce realistic actual results, but no assessment is made against the accuracy of the data. An example of this is where a customer is investigating an area but has no real idea of what to expect, e.g. assessing poor GPES reference: NIC V5Z0L Page 18 of 23

19 Confidential Information Customer Request Output Data Provider Output Dataset Direction Extracted Data Extraction Requirement Feasibility Testing Personal Confidential Data Patient Identifiable quality of data. It might be, for example, a precursor to a more detailed Customer Requirement. See Patient Identifiable Data and Personal Identifiable Data. This is the technical name for the data file(s) that GPES delivers to the customer. The data in the Customer Request Output (CRO) is based on the requirement set out in this document. The Data Provider Output (DPO) is the data that general practice system suppliers extract from general practice clinical systems and submit to GPES. The DPO is based on the data extraction specification (referred to as the Extraction Requirement ) that GPES circulates to general practice system suppliers. A collection of data items standardised against a set of attributes. Each record within the dataset pertains to one instance of the dataset entity. A Direction is a form of delegated legislation, where an Act of Parliament (or other legislation) grants the power to a minister or other designated body to give legally binding orders with which the recipient must comply. The National Health Service England hereby gives the following Directions to the Health and Social Care Information Centre in exercise of the powers conferred by sections 254(1), (3) and (6), 260 (4)(a), 262(1), (3)(a), (5),(7)and 304(9), (10) and (13) of the Health and Social Care Act See Data Provider Output. This is the technical name for the specification that describes to general practice system suppliers the data that should be extracted from general practice systems and how that data should be sent to GPES, (or another appropriate destination). Feasibility testing assesses whether the proposed information requirements are likely to derive good quality data, once the requirement is live. The feasibility testing is undertaken during the development phase of the requirement and carried out on sample databases, which contain patient-level data from a sample of general practices. See Patient Identifiable Data and Confidential Information. Information that can identify one person. This could be one piece of data for example a person s name or a collection of information 8 NHS England, The Health and Social Care Information Centre (Establishment of Information Systems for NHS Services: Collection and Analysis of Primary Care Data) Directions [Online] Available at: [Accessed 30 January 2014] GPES reference: NIC V5Z0L Page 19 of 23

20 Data Scheduled Query Instance for example NHS Number, name, address and date of birth. A Scheduled Query Instance (SQI) is an instance of a data extract, as scheduled against general practice clinical systems. GPES reference: NIC V5Z0L Page 20 of 23

21 12. Appendix C Read codes Purpose of appendix The purpose of this appendix is to provide the objection Read codes that are to be used for this extraction requirement. Appendix content Description READ2 CTV3 Dissent from secondary use of general practitioner patient identifiable data Dissent withdrawn for secondary use of general practitioner patient identifiable data Dissent from disclosure of personal confidential data by Health and Social Care Information Centre Dissent withdrawn from disclosure of personal confidential data by Health and Social Care Information Centre 9Nu0. 9Nu1. 9Nu4. 9Nu5. XaZ89 XaZ8A XaaVL XaaVM GPES reference: NIC V5Z0L Page 21 of 23

22 13. Appendix D Recording Objection Codes Purpose of appendix The purpose of this section is to provide details of how a patient can record an objection code and what data will be extracted for each objection code. Appendix content Type 1 and type 2 objection codes Where a type 2 objection code is recorded in a GP System, teams within the HSCIC will be responsible for preventing identifiable data about that patient being released for purposes other than direct care. Health Datasets Health Datasets Matching Process Patient identifies they wish to record or withdraw an objection to their patient identifiable data leaving the general practice and/or the HSCIC. GP records objection code on clinical system Aggregated Counts The total number of patients at each general practice. The number of patients at each general practice who have currently recorded a type 1 objection. The number of patients at each general practice who have currently recorded a type 1 withdrawn objection. The number of patients at each general practice who have currently recorded a type 2 objection. The number of patients at each general practice who have currently recorded a type 2 withdrawn objection. Type 2 objection code NHS Number General Practice ID Type 2 objection code Date type 2 objection code recorded on GP system Data sent to DME Type 1 and 2 objection codes recorded on GP System. Data Extract GPES Where a type 1 objection code is recorded in a GP System, then no identifiable data will be extracted for purposes other than direct care. Where a type 2 objection code is recorded in a GP System, then a number of data items will be extracted including NHS Number to prevent disclosures of identifiable data for purposes other than direct care. GPES reference: NIC V5Z0L Page 22 of 23

23 14. Appendix E GPES data extraction and delivery Purpose of appendix The purpose of this section is to provide details of the data extraction and delivery of data regarding objection codes to support this extraction requirement. Appendix content Data access and storage The data extracted via GPES will be stored in the HSCIC s Data Management Environment (DME). Data processing GP Systems GP Systems GP System Patient identifies they wish to record or withdraw an objection to their patient identifiable data leaving the general practice and/or the HSCIC. The objection code is added to their general practice record. HSCIC DME Environment GPET-Q CRO File Landing Stage Data Quality Check POM Dataset Patient Objections Extract Type 1 objects to data in identifiable form leaving the practice for purposes other than direct care Type 2 objects to data leaving HSCIC in identifiable form Secure Data Management Environment (DME) System Level Security Policy Confirm all records have transferred with no data loss and agreed data quality rules applied Processing of data After the data has been extracted from general practices and processed it is then forwarded to a secure data store in DME held by the HSCIC. The data will be held for processing and a series of data quality checks to take place to ensure the data received is in the expected format and that there is no data corruption. GPES reference: NIC V5Z0L Page 23 of 23