Evidence submitted by the Royal College
of General Practitioners (EPR 17)
1. The College welcomes the opportunity
to comment on the inquiry into the electronic patient record and
it use.
2. The Royal College of General Practitioners
is the largest membership organisation in the United Kingdom solely
for GPs. It aims to encourage and maintain the highest standards
of general medical practice and to act as the voice of GPs on
issues concerned with education, training, research, and clinical
standards. Founded in 1952, the RCGP has over 26,000 members who
are committed to improving patient care, developing their own
skills and promoting general practice as a discipline.
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 new systems
3. The RCGP supports the creation of a summary
care record on the national electronic record system and the greater
use of local detailed electronic records within organisations.
4. We recognise that the appropriate content
for any summary is context dependent: ie it depends on the purpose
of the summary and the identity of the person for whom it is written.
Consequently the scope of the summary care record will need to
be limited, since it is a largely context-free item.
5. We are aware that General Practice records
necessarily contain large amounts of information relating to social,
family, and relationship matters. This needs to be recognised
in conversations about what elements of the local detailed care
record should be shared.
6. Consequently, we are in favour of maintaining
organisational boundaries around information in the detailed care
record. We are also strongly in favour of giving the patient control
over what information of theirs is shared. We see the health record
as the property of the individual, not of their medical advisers,
nor the Secretary of State.
Who will have access to locally and nationally
held information and under what circumstances?
7. Access controls are determined by the
principles of Legitimate Relationship and Role Based Access Control.
Provided that these are properly implemented and applied in practice
they ensure that only a clinician who is, at that time, properly
involved in the care of that patient has access to the record.
This should apply to both locally and nationally held information.
8. The concept of sealed envelopes offers
a mechanism for some items of information to be hidden from specified
groups of clinicians, under the patient's control. The technical
implementation of sealed envelopes remains uncertain. Clinicians
may, if they feel it is justified, "break the glass"
and inspect the contents of a sealed envelope.
9. One concern is that the sanctions for
inappropriate access to records are retrospective through an audit
trail and alerts. This deters, but does not prevent inappropriate
access.
10. We feel that it is very important for
the patient to retain control of who sees which part of their
records. "My Health Space", by letting the patient view
what is in their record, is an important point of this process.
11. We are aware that some groups of clinicians
feel that this patient centred approach may hinder their ability
to care for patients. We feel that utilitarian and pragmatic arguments
of this sort should not over-ride the principles of privacy and
self determination. From the point of view of patient safety,
an assumption of incomplete knowledge (ie awareness that one does
not know everything about a patient) is preferable to a false
assumption that a particular record is complete and accurate.
Whether patient confidentiality can be adequately
protected
12. Security of information is governed
by a combination of technical measures and proper use of the system
by practitioners. The more open a system, in terms of number of
users and ease of movement of information across organisational
boundaries, the more security depends on good practice in terms
of information governance. There is a large element of education
and training required to support this, and it is not clear if
this is being addressed by CFH.
13. There is again a conflict here between
the rights of the patient to confidentiality and the convenience
of clinicians. We feel that increased patient understanding of
these issues through unbiased information campaigns, and placing
the patient in control of access to specific items in their record,
constitutes the best way forward.
How data held on the new systems can and should
be used for purposes other than delivery of care eg clinical research
14. The College recognises the potential
value of using pooled data for epidemiological research, for assessing
the health needs of populations as well as for other purposes.
15. It is essential that no patient-identifiable
data is used in this way, that patients are aware of this usage
of data, and that such secondary uses of information lie within
the law.
16. As with all other usage of shared information,
secondary usage will only be of value if the original contributing
records are accurate and correctly expressed in a coding language
that is reliably interpreted by the recipient system. Use of clinical
terms varies among different professional groups. There is another
training issue that is to do with consistency of coding and preservation
of meaning in electronic records that are transferred from place
to place. Again it is not clear that CFH have fully appreciated
this need nor planned to address this training need. The wide
diversity of potential contributors to this pooled information
is a risk to the utility of the data.
Current progress on the development of the NHS
Care Records Service and the National Data Spine and why delivery
of the new systems is up to two years behind schedule
17. Opinions on this have been expressed
by organisations ranging from the British Computer Society to
Private Eye.
18. There is a general agreement that the
original timescales were unrealistic and that there was a lack
of understanding among officials and politicians of the degree
of complexity that characterises the health informatics domain.
19. We feel that there does remain a reservoir
of goodwill among clinicians towards the aim of joined up electronic
health records in the NHS. There was inadequate engagement with
clinicians in the early stages of the National Programme for IT.
It is to be hoped that this mistake is not perpetuated.
20. I acknowledge the contributions of Dr
Paul Robinson and Professor Nigel Sparrow towards the above comments.
While contributing to this response, it cannot be assumed that
those named all necessarily agree with all of the above comments.
Dr Maureen Baker
Honorary Secretary of Council, Royal College of General
Practitioners
14 March 2007
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