Select Committee on Health Written Evidence

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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