Information Governance Policy

Policy Policy Number / Version: v2.0 Ratified by: Audit Committee Date ratified: 25 th February 2015 Review date: 24 th February 2016 Name of originator/author: Name of responsible committee/individual: Target audience: CSU Team Audit Committee/Chief Finance Officer All staff, including temporary staff and contractors 1 of 21

VERSION CONTROL Policy Name: Version Valid From Valid To Document Path/Name 1.0 15 May 2013 14 May 2014 2.0 25 Feb 2015 24 Feb 2016 2 of 21

1. Introduction 2. Scope is a vital asset, both in terms of clinical management of individual patients and the efficient planning and management of services and resources. It is therefore of paramount importance to ensure that information is effectively managed and that appropriate policies, procedures, management accountability and structures provide a robust governance framework for information management. This policy provides assurance to the CCG and to individuals that personal information is dealt with legally, securely, efficiently and effectively, in order to deliver the best possible care. The CCG will establish and maintain this policy and the associated procedures to ensure compliance with the requirements contained in the Health and Social Care Centre s (HSCIC) Toolkit. This policy, and its supporting procedures, are fully endorsed by the Board through the production of these documents and their minuted approval. 2.1 This policy covers all aspects of information within the organisation, including but not limited to: Personal - Patient/client/service user information - Employee information Organisational 2.2 This policy covers all aspects of handling information, including but not limited to: Structured record systems paper and electronic Transmission of information fax, email, other forms of electronic transmission such as FTP, post and telephone 2.3 This policy covers all information systems purchased, developed and managed by or on behalf of the CCG, and any individual directly employed or otherwise by the CCG. 2.4 The key component underpinning this policy is the annual action plan arising from a baseline assessment against the standards set out in the HSCIC c Toolkit. 2.5 This policy cannot be seen in isolation as information plays a key part in corporate governance, strategic risk, clinical governance, Caldicott principles, service planning, performance and business management. 3 of 21

2.6 The policy therefore links into all these aspects of the CCG and should be reflected in these respective strategies/policies. 3. Principles The CCG recognises the need for an appropriate balance between openness and confidentiality in the management and use of information. The CCG fully supports the principles of corporate governance and recognizes its public accountability. It equally places importance on the confidentiality of, and the security arrangements to safeguard, both personal information about patients and staff and commercially sensitive information. The CCG also recognises the need to share patient information with other health organisations and other agencies in a controlled manner consistent with the interests of the patient and, in some circumstances, the public interest. The CCG believes that accurate, timely and relevant information is essential to deliver the highest quality health care. As such it is the responsibility of all CCG employees to ensure and promote the quality of information and to actively use information in decision making processes. There are 4 key interlinked strands to the information governance policy: Openness and transparency Legal compliance security and Risk Quality assurance 3.1 Openness & Transparency The CCG recognises the need for an appropriate balance between openness and confidentiality in the management and use of information. Patients will have access to information relating to their own health care, options for treatment and their rights as patients. There will be clear procedures and arrangements for handling queries from patients and the public. The CCG will have clear procedures and arrangements for liaison with the press and broadcasting media. Integrity of information will be developed, monitored and maintained to ensure that it is appropriate for the purposes intended. Availability of information for operational purposes will be maintained within set parameters relating to its importance via appropriate procedures and computer system resilience. 4 of 21

The CCG regards all identifiable information relating to patients as confidential. Compliance with legal and regulatory framework will be achieved, monitored and maintained. The CCG regards all identifiable information relating to staff as confidential except where national policy on accountability and openness requires otherwise. The CCG will ensure that when person identifiable information is shared, the sharing complies with the law, guidance and best practice and both service users rights and the public interest are respected. Non-confidential information relating to the CCG and its services is available to the public through a variety of media, in line with the Freedom of Act and Environmental Regulations. The CCG will establish and maintain policies and procedures to ensure compliance with the Data Protection Act, Human Rights Act, the common law duty of confidentiality and the Freedom of Act and Environmental Regulations. training including awareness and understanding of Caldicott principles and confidentiality, information security, records management and data protection will be mandatory for all staff. governance will be included in induction training for all new staff. 3.2 Legal Compliance The CCG regards all identifiable information relating to patients as confidential. The CCG will undertake or commission annual assessments and audits of its compliance with legal requirements through the IG Toolkit. The CCG regards all person identifiable information relating to staff as confidential, except where national policy on accountability and openness requires otherwise. The CCG will establish and maintain procedures to ensure compliance with the Data Protection Act, Human Rights Act and common law confidentiality. The CCG will establish and maintain procedures for the controlled and appropriate sharing of patient information with other agencies, taking account of relevant legislation (e.g. Health and Social Care Act, Crime and Disorder Act, Protection of Children Act). The CCG has a comprehensive range of procedures supporting the information governance agenda; reference must be made to these alongside this policy. Legal and professional guidance should also be considered where appropriate. 5 of 21

3.3 Security and Risk The CCG will establish and maintain procedures for the effective and secure management of its information assets and resources. The CCG will undertake or commission annual assessments and audits of its information and IT security arrangements through the IG Toolkit framework. The CCG will promote effective confidentiality and security practice to its staff through procedures and training. The CCG will establish and maintain incident reporting procedures and will monitor and investigate all reported instances of actual or potential breaches of confidentiality and security. The CCG will establish and maintain Risk Management and reporting procedures and will have in place risk control and monitor all reported information risks. 3.4 Quality Assurance The CCG will establish and maintain procedures for information quality assurance and the effective management of records. The CCG will undertake or commission annual assessments and audits of its information quality and records management arrangements in line with IG toolkit requirements. The CCG will ensure that information is managed throughout its lifecycle of creation, retention, maintenance, use and disposal. The CCG will ensure that information is effectively managed so that it is accurate, up to date, secure, retrievable and available when required. Employees are expected to take ownership of, and seek to improve, the quality of information within their services. quality should be assured at the point of collection. The CCG will promote information quality and effective records management through procedures and training. 4. Responsibilities It is the role of the CCG Board to define the CCG policy in respect of, taking into account legal and NHS requirements. The Board is also responsible for ensuring that sufficient resources are provided to support the requirements of the policy. 6 of 21

The Chief Officer as Accountable Officer of the CCG has overall accountability and responsibility for in the CCG and is required to provide assurance, through the Annual Statement that all risks to the CCG, including those relating to information, are effectively managed and mitigated. The Senior Risk Owner (SIRO) is an Executive Director of the CCG Board. The SIRO is expected to understand how the strategic business goals of the CCG will be impacted by information risks. The SIRO will act as an advocate for information risk on the Board and in internal discussions, and will provide written advice to the Accounting Officer on the content of their Annual Statement in regard to information risk. The SIRO will provide an essential role in ensuring that identified information security threats are followed up and incidents managed. They will also ensure that the Board and the Accountable Officer are kept up to date on all information risk issues. The role will be supported by the Midlands and Lancashire Commissioning Support Unit by the Team, the CCG Caldicott Guardian, and a network of Asset Owners and Asset Administrators, although ownership of Risk assessment process will remain with the SIRO. Asset Owners (IAOs) shall ensure that information risk assessments are performed at least once each quarter on all information assets where they have been assigned ownership, following guidance from the SIRO on assessment method, format, content and frequency. IAOs shall submit the risk assessment results and associated plans to the SIRO for review, along with details of any assumptions or external dependencies. Mitigation plans shall include specific actions which expected completion dates, as well as an account of residual risks. The organisation must have a Caldicott Guardian. This role is an amalgamation of management and clinical issues which helps to ensure the involvement of healthcare professionals in relation to achieving improved information governance compliance. The Caldicott Guardian has responsibility for ensuring that all staff comply with the Caldicott Principles and the guidance contained in the Health and Social Care Centre s (HSCIC) document A Guide To Confidentiality in Health and Social Care. The Caldicott Guardian will guide the organisation on confidentiality and protection issues relating to patient information. This role is pivotal in ensuring the balance between maintaining confidentiality standards and the delivery of patient care. The Caldicott Guardian will also advise the Board on progress and major issues as they arise. The Audit Committee is responsible for overseeing day to day issues, developing and maintaining policies, standards, procedures and guidance, coordinating and raising awareness of in the CCG. All managers within the CCG are responsible for ensuring that the policy and supporting procedures are built into local processes to ensure on-going compliance. s are also 7 of 21

responsible for ensuring that staff attend mandatory awareness training and refresher training as required. All staff, whether permanent, temporary or contracted, are responsible for ensuring that they are aware of the requirements incumbent upon them and for ensuring that they comply with these on a day to day basis. 5. Training/Awareness governance will be a part of an induction process. All new and existing staff will receive annual mandatory training and guidance on information governance, which will include Caldicott and confidentiality, data protection, information security and Freedom of. 6. Monitoring/Audit The CCG will monitor this policy and related strategies and procedures through the Audit Committee. As assessment of compliance with the requirements of the Toolkit (IGT) will be undertaken each year. The CCG will identify staff to undertake Administrator, Reviewer and User roles as described in the IGT. The Audit Committee will ensure implementation of the Strategy. Annual reports and proposed action/development plans will be presented to the CCG Board for approval prior to submission of the IGT. The policy and associated procedures will be subjected to both internal and external audit reviews. The CCG will ensure that the support infrastructure for the SIRO is in place, and is kept under regular review. 7. Management management across the organisation will be co-ordinated by the Audit Committee. The responsibilities of the Audit Committee will include, but not be limited to: Recommending policies and procedures to the appropriate CCG Board for approval. Recommending the annual submission of compliance with requirements in the IGT and related action plan to the CCG Board for approval. 8 of 21

Co-ordinating and monitoring the Strategy across the organisation The Audit Committee will endorse Strategy for the CCG. 8. Improvement Plan The Audit Committee will be responsible for monitoring the improvement plans and associated progress. The improvement plan is fundamental to the organisation achieving the Toolkit. It is essential that the Audit Committee are updated on the progress of the plan and of any associated risks which will affect the organisations ability to achieve IG Toolkit compliance. The Improvement Plan can be found in Appendix 2. 9. Review This policy and associated strategy and procedures will be reviewed on an annual basis or earlier if appropriate, to take into account any changes to legislation that may occur, and/or guidance from the Department of Health and/or NHS Executive. 10. Supporting Procedures Handbook. 9 of 21

Appendix A - Management Framework Senior Roles within the CCG Requirement Accountable Officer: Dr Caron Morton, Chief Officer Detail The Chief Officer as Accountable Officer of the Shropshire CCG and has overall accountability and responsibility for in the CCG and is required to provide assurance through the Annual Statement that all risks to the organisation, including those relating to information, are effectively managed and mitigated. Senior Risk Owner: Donna McGrath, Chief Finance Officer The Senior Risk Owner (SIRO) is an Executive Director of Shropshire CCG Board. The SIRO is expected to understand how the strategic business goals of the CCG may be impacted by information risks. The SIRO will act as an advocate for information risk on the Board and in internal discussions, and will provide written advice to the Accountable Officer on the content of their Annual Statement in regard to information risk. The SIRO will provide an essential role in ensuring that identified information security threats are followed up and incidents managed. They will also ensure that the Board and the Accountable Officer are kept up to date on all information risk issues. The role will be supported by the Midlands and Lancashire Commissioning Support Unit Team and the Caldicott Guardian, although ownership of the Risk Agenda will remain with the SIRO. The SIRO will be supported through a network of Asset Owners and Administrators who have been identified and trained throughout the organisation. Caldicott Guardian: Bharti Patel- Smith, Director of & Involvement Organisational Hayley Gidman, Lead (Midlands and Lancashire Commissioning Support Unit) Shropshire CCG Caldicott Guardian has particular responsibility for reflecting patients interests regarding the use of patient identifiable information and to ensure that the arrangements for the use and sharing of clinical information comply with the Caldicott principles. The Caldicott Guardian will advise on lawful and ethical processing of information and enable information sharing. They will ensure that confidentiality requirements and issues are represented at Board level and within the Shropshire CCG overall governance framework. The key purpose of the role is to ensure Shropshire CCG successfully manages the risks associated with & Security. The post holder will ensure the establishment of corporate standards and a consistent CCG wide approach to & Security and will be responsible for assuring the implementation of a range of policies, processes, monitoring audits and training and awareness mechanisms to ensure a high level of compliance with external assessments including the Toolkit, Care Quality Commission and the NHS Litigation Authority. The Senior and Security will also be responsible for the implementation and ongoing development of the SIRO framework, ensuring that IAOs and IAAs fulfil their duties and promote an information risk management approach when dealing with information assets. 10 of 21

Key Policies Policies set out the scope and intent of the organisation in relation to the management of. Organisational Ilse Newsome, Deputy Chief Finance Officer Ratification Schedule: Policy Hand Book The key purpose of the role is to ensure Shropshire CCG successfully implements a range of policies, processes, monitoring audits and training and awareness mechanisms to ensure a high level of compliance with & Security. The post holder will ensure the implementation of corporate standards and a consistent organisation wide approach to & Security. Audit Committee 25/02/2015 25/02/2015 Key Bodies A group, or groups, with appropriate authority should have responsibility for the IG agenda. Resources Details of key staff roles Policies are communicated to appropriate staff via the membership of the groups at which they are ratified, and through internal communications utilising the CCGs intranet site and staff briefing announcements. All policies are available on the CCGs shared network drive and on the external website at http://www.shropshireccg.nhs.uk/policies#ig. Audit The Audit Committee is responsible for overseeing day to day Committee issues, developing and maintaining policies, standards, procedures and guidance, coordinating and raising awareness of in the CCG. Dedicated Staff Support Officer Kate Faulkner-Elliott Kate.faulkner-elliot@nhs.net 07525 613008 Security Andy Thompson andy.thompson1@nhs.net 07702 967496 Framework Details of how responsibility and accountability for IG is cascaded through the organisation. Asset Owners Emma Styles emmastyles@nhs.net 07825 716409 Lead Hayley Gidman hayley.gidman@nhs.net 07809 320323 Asset Owners are senior individuals involved in running the relevant business. The IAOs role is to: - Understand and address risks to the information assets they own ; and - Provide assurance to the SIRO on the security and use of these assets. Asset Owners have been nominated across the whole organisation and have received specialist information risk training to allow them to be effective in their role. 11 of 21

Asset Administrators The Asset Administrators and will: - Ensure that policies and procedures are followed - Recognise potential or actual security incidents - Consult their IAO on incident management - Ensure that information assets registers are accurate and maintained up to date. Training and Guidance Staff need clear guidelines on expected working practices and on the consequences of failing to follow policies and procedures. The approach to ensuring that all staff receive training appropriate to their roles should be detailed. Handbook Training for all staff Asset Owners have received specialist information risk training to allow them to be effective in their role. Purpose of the Handbook: To inform staff of the need and reasons for keeping information confidential To inform staff about what is expected of them To protect the Organisation as an employer and as a user of confidential information This Handbook has been written to meet the requirements of: The Data Protection Act 1998 The Human Rights Act 1998 The Computer Misuse Act 1990 The Copyright Designs and Patents Act 1988 A Guide To Confidentiality in Health and Social Care (HSCIC) This Handbook has been produced to protect staff by making them aware of the correct procedures so that they do not inadvertently breach any of these requirements. If the Handbook is breached then this may result in legal action against the individual and/or Organisation as well as investigation in accordance with the Organisation s disciplinary procedures. The Handbook will be disseminated to all staff working for the CCG and they will be required to acknowledge that they have received and understand the document. In future, any new starters to the organisation will receive a copy of this with their contract. Both should be signed and returned to their line manager and kept on file. All staff will receive basic IG training, initially via the Introduction to module of the online training tool (https://www.igtt.hscic.gov.uk/igte/index.cfm). Annual refresher training will then be conducted through face to face training sessions facilitated by the Support Officer. Specialist IG training As required specialist IG training will be provided across the organisation for those staff that are given additional responsibility for IG within their areas. Current specialist training includes: Risk Training Privacy Impact Assessments Caldicott and Data Protection Training 12 of 21

Incident Management Clear guidance on incident management procedures should be documented and staff should be aware of their existence, where to find them, and how to implement them. Documented Procedures and Staff Awareness Incident Management in the CCG is covered in the following organisational policies and Procedures: Policy Handbook Staff awareness is raised through the following ways: Staff Induction Training Risk Training Caldicott and Data Protection Training 13 of 21

Appendix B CCG Improvement Plan 2014-15 Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement Management Training Delivery of all staff IG training Deliver Face to face refresher IG training within the CCG Implement new starter IG induction Process, including ensuring that the e-learning tool is completed as part of the induction. Sessions booked for: - 31/10/2014-20/11/2014-06/01/2015 Jan/Feb 2015 Joint session between Telford & Wrekin and Shropshire CCGs to catch anyone who has not been able to attend the previous three dates CSU Operational Officer CSU Strategic CCG Resource: All Staff 12-134 12-230 12-234 12-340 12-345 12-420 Provide Senior Risk Owner (SIRO) Training November 2014 CSU Operational Security CSU Strategic 14 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement CCG Resource: SIRO Promotional & Communication Campaign Raise the profile of IG Raise awareness of national IG legislation and guidance Staff Engagement Officer Visual presence within the CCG Base Meet all new CCG new starter s and conduct an IG induction. Development of promotional materials including the design of Screensavers and posters. Ensure the CCG website meets the requirements of privacy and fair processing notices. Bi-monthly IG Newsletter to be issues to all staff Training sessions to cover the legislative background to IG and any changes to guidance that has been issued. Use surveys to understand staffs perception of IG and the general satisfaction levels in relation to the IG communications. December 2014 December 2014 October 2014 CSU Operational Officer CSU Strategic CCG Resource: All Staff 12-130 12-131 12-133 12-134 12-231 12-232 12-234 12-235 12-237 12-250 12-346 12-347 12-348 12-349 12-420 Confidentiality & Data Protection Assurance Confidentiality and Security Audits Identification of those areas within the CCG where patient information is routinely accessed and the Contacting all Asset Owners and Assistants to provide updates the processes and systems used within their departments where patient information is regularly accessed. This will be throughout the year. Audit findings to be complete and reported to the CCG by February 2015. CSU Operational 12-231 12-235 12-344 12-346 12-347 15 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement systems used to do so. Smart Card Audit completed in conjunction with the review of the CCG Asset Registers. Where it identified that staff are accessing patient or confidential information an audit of those accesses will be completed. Ensure that where staff have a smart card that the appropriate role based access codes are on the card and that historical access codes from previous roles have been removed. October 2014 Officer CSU Strategic Security CCG Resource: All Staff 12-348 Identification of the access controls in place on the systems used by the CCG including the level of monitoring that is undertaken. Testing the information recorded within the Asset Registers as a true and accurate reflection using the Plan, Do, Check, Act model of Security Assurance. Spot Check Audits Contact individual system administrators and/or IT Provider to ensure appropriate controls are in place To be completed during the final review of asset registers for the financial year. Contacting information Assets owners/assistants to review and record any changes from previously. Carryout an Security Audit to test the recorded information. Completing regular spot checks within the CCG offices early morning Checking for hardware unattended from the previous working day February 2015 16 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement Ensuring all desks adhere to the clear desk policies Reporting all findings to CCG SIRO/IG Lead Following up any actions required Lifecycle Management Where necessary additional training following audit to highlight risks and findings, promoting best practice Shared Drive & Records Management Standards Work with the CCG to move away from the legacy drive and to look to set the standards and structures in place for a CCG shared drive that meets the business needs. (This may not be relevant to all CCGs) Development of best practice guidelines for staff in relation to records management practices to include: Work with the Records Management Lead to determine what the business requirements are and to use this to inform the structure that needs to be implemented. Support the CCG with the ongoing set up of the shared drive providing specialist Records Management advice as required. This will also include make recommendations as required. Ensure folders identified as being unsecure from asset register exercise are held in the appropriate area with restrictions where applicable. Work with the CCG to understand whether they wish to raise awareness of records management best practice or whether they wish to make an organisation decision to implement the nest practice records management Oct 2014 throughout the information asset review work programme actions to be completed as issues are found. CSU Operational Officer CSU Strategic CCG Resource: All Staff National Best Practice for Corporate Records Management 17 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement - Folder & File Naming Conventions standards as policy. - Version Control - Retention of Records - Destruction of records Security Assurance Project Management & Privacy Requirements Ensuring that the Privacy Impact Assessment process is embedded and that the identification of the need to complete an assessment is met. Ensure that the PIA forms are included within the project initiation procedures and procurement processes. Measures should be taken to raise the awareness of this matter amongst those teams who are involved in the implementation of new projects, processes or services. Communications raising the profile as PIA: - Team Briefings - Newsletters - As part of the Asset Reviews - Training Nov 2014 CSU Operational Officer CSU Strategic Security CCG Resource: Project & Commissioning s 12-237 Risk Assurance Work Programme 2014-15 Ensure that there is an effectively continued information risk processes; there should be a comprehensively scoped and formally Review the existing list of IAAs and IAOs and update as necessary based on staffing changes and the requirements of the business. Oct 2014 Transfer information from previous Oct 2014 CSU Operational Officer 12-341 12-350 12-351 18 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement documented programme that considers the security risks to Assets. Asset Register to new template Conduct workshops/drop in sessions for IAAs and IAOs Review of Assets for departments. Transfer information from previous Data Flow Mapping to new template where a data flow had previously been recorded and applicable information had been recorded Oct 2014 CSU Strategic Security CCG Resource: IAO, IAAs and the SIRO Work with IAAs and IAOs to review, update and add to the Data Flow Mapping spreadsheet. Oct 2014 Contracts and sharing Agreements Senior Risk Owner Reports Ensure that contacts and sharing agreements are in place Reports to be sent to the SIRO on a quarterly basis, informing them of Progress against the Risk Work Programme Highlighted areas of information risk Any incidents that have occurred during the previous quarter Provide a checklist and templates which can be used by the CCGs to ensure that all requirements are included and adequately addressed in any new contracts or sharing agreements Review any existing (or new) contracts or sharing agreements (specifically tier 2 Quarterly Nov 2014 as identified via Data Flow Mapping CSU Operational Officer CSU Strategic 19 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement agreements) against the Sharing checklist Put plans in place to ensure where contracts and agreements are not in place or need amendment that this is done within the IG toolkit reporting year. Security CCG Resource: IAO, IAAs and the SIRO IG Incident Management Establish and implement incident reporting processes in line with the national IG Serious Incident Guidance Work with CCG to ensure adequate, relevant information is recorded regarding the incident/near miss. Update entries made in the reporting tool to reflect investigation and closure of the incident Verify incident severity assessments Support IGSO with the investigation of Level 0 or Level 1 incidents. Operational Officer Strategic Security Support the investigating officer in the investigation of Level 2 incidents. Technology Technology Toolkit Requirements and Business Continuity Requirements Working in conjunction with the IT Lead, to identify the measures that can be taken to obtain appropriate assurance from each of the IT services Ensuring all policies and processes are up to date with the IT Providers. Working with the relevant contacts within the IT Provider for relevant evidence CSU Operational Security CSU Strategic 12-340 12-343 12-344 12-346 12-347 12-348 20 of 21

Improvement/Requirement Measurable Action Target Dates Lead/Resources IG Toolkit elements met by this requirement 21 of 21