Data Protection Bill [HL]

Written evidence submitted by IHRIM (DPB41)

Dear Sir/Madam

Re: Changes to the pricing charges under the new General Data Protection

Regulations (GDPR)

I write on behalf of the Institute of Health Records and Information Management, a professional body that represents members working in administrative departments within the Health sector.

Some of our members work within dedicated departments that manage Subject Access Requests and currently charge between £10 and £50 upwards for the provision of disclosing personal identifiable information (PID), and more often than not this is for the release of patient records.

At present, the process of identifying and safely releasing the appropriate PID is a very complex and time-consuming series of processes which is very labour intensive and therefore expensive.

It is more often the income that is generated that pays for the staff who provide this service, becoming nearly cost neutral. It is not uncommon for departments to be bringing in an income of anywhere between £40,000 and £100,000 per annum and this not only pays for the staff but resources such as paper, ink cartridges, discs, postage and packaging. Typically, a department is ‘manned’ by a Supervisor and two/three clerical officers.

The new GDP regulations state that organisations must provide a copy of the information free of charge, the removal of this fee is a significant change from the existing rules under the DPA 1998. With the information being free of charge it is anticipated that the number of requests will increase and solicitors will, as a matter of course request everything as there will be no charge associated with their request (an anticipated increase of between 25 and 40% has been predicted). There is also the reduction in the amount of days that SARs have to be disclosed from 40 days to one month, adding further pressure.

So the scenario Trusts will be left with is an increase in workload, a reduction in turnaround time and potentially all with no income to offset the costs!

The Institute of Health Records and Information Management would like to bring this situation to your attention and ask that dispensation be given to the Health Sector in respect of providing Subject Access Requests free of charge.

This situation is going to weaken further an already financially challenged organisation and will almost certainly become a financial burden that will not be able to be sustained without the income to provide this service.

We would very much welcome your comments on this.

March 2018


Prepared 20th March 2018