Evidence submitted by the Faculty of Family
Planning and Reproductive Health Care (EPR 18)
EXECUTIVE SUMMARY
The Faculty of Family Planning and Reproductive
Health Care (FFPRHC) of the Royal College of Obstetricians and
Gynaecologists contributes to the National Advisory Group for
Connecting for Health, and has been concerned about the slowness
and uncertainty regarding the development of sealed envelopes
to keep people's sexual and reproductive health secure. The majority
of community contraceptive services are currently not supplied
with computerised systems to manage appointments, collect and
submit statistical returns, and do not have the capacity to operate
electronic records; there is concern that the implementation of
the EPR will depend on PCTs finding funds to purchase and support
computers linked across localities, and uncertainties about details
of what will be required have hampered services looking at interim
solutions.
1. What patient information will be held
on the new local and national electronic record systems, including
whether patients may prevent their personal data being placed
on systems:
1.1 Members of the FFPRHC work in areas
of sensitive public health. This may be in services providing
contraception and sexual health operating as one unit within a
single unit commissioned by one health organization, or as a combined
service across organizations.
1.2 Research has shown that concerns about
confidentiality, particularly where young people have chosen to
access community/alternative services rather than their GPs, are
paramount in whether or not health-seeking behaviour and disclosure
of areas which may need protection, will be sought.
1.3 Our understanding is that sexual and
reproductive health data will be on a separate "work group"
to other community or hospital electronic records, with access
only by those working in that service.
1.4 Many people access our services wishing
to protect their identity, and register with false names, dates
of birth and addresses, which may result in duplicate registrations
even across different sites of the same service.
1.5 If NHS number is to become a mandatory
field, there are issues about people not registered with GPs,
or who do not know this number.
2. Who will have access to locally and nationally
held information and under what circumstances:
2.1 Our understanding is that at least initially
no sexual health information will be uploaded onto the National
spine, and that locally the only people to see any information
about access to our services are those with a legitimate relationship
defined by the work group, and not accessible by other people
working within a community or hospital setting.
3. Whether patient confidentiality can be
adequately protected;
3.1 There are issues about the timing and
operation of sealed envelopes which need to be determined before
clinicians can have confidence to use any local or national systems.
3.2 Community services are likely to need
to have access as a team rather than an individual to protected
data due to the way the services run (ie often open access and
as non-appointment sessions).
3.3 Until this is agreed, it is difficult
to envisage adequate continuity of patient care whilst preserving
confidentiality.
4. How data held on the new systems can and
should be used for purposes other than the delivery of care eg
clinical research;
4.1 Central statistical returns (KT31 for
contraception and KC60 for sexually transmitted infections) should
as now be on non-identifiable aggregate data.
4.2 The Common Data Set for Sexual Health
is being developed to replace these returns which currently do
not capture all the public health input in the 2 settings.
Alyson Elliman
Faculty of Family Planning and Reproductive Health
Care of RCOG
14 March 2007
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