By Tim Dunn, General Manager, FairWarning.A few weeks after the publication of the Caldicott2 recommendations and having had time to review them in detail, I can only applaud the outcome of the huge task undertaken by Dame Fiona and her team. Not only does the report mark a decisive step forward for patient privacy, it lays the foundation for building a secure and trusted digital healthcare system and the achievement of a paperless NHS by 2018.
The widespread use and continued growth of electronic healthcare systems, coupled with the free flow of information are essential for the sustainable delivery of better outcomes for patients. This can only be successful if clinicians and patients have confidence that sensitive data is secure. The implementation of the Caldicott recommendations will lead to better care through privacy and respect for the patient.
In particular I welcome the recommendation to 'notify patients when their records have been breached'. This is a key element of patient privacy rights and would truly represent a turning point for UK healthcare. Furthermore, the recommendation to enable patients to review access to their records would also make the UK the first nation in the world to mandate this requirement and mark a step towards transparent healthcare.
A further decisive move forward for patient privacy, and ensuring the sustainable growth of electronic healthcare, was in the fact that the review identified audit controls and access reporting as top priorities. Auditing and monitoring access to patient records is absolutely vital for gaining the trust of patients and hence enhancing the reputation of healthcare providers in a market that is becoming more competitive.
Need to go further still
Although the Caldicott2 recommendations represent a monumental milestone in the journey of the NHS, we now need to see those recommendations implemented. In some areas though I would actually call for further action, such as:
The introduction of robust standards for audit trails
The implementation of robust standards for audit trails will be a key component in the delivery of an electronic healthcare model built on the principle of interoperable systems and widespread sharing of data. Interoperability increases the risk of security breaches and, as such, underlines the need for common and robust standards for audit trails to underpin all healthcare applications.
Reinforcing a culture of privacy in the NHS
There is an urgent requirement for educating staff who handle personal health information. Caldicott Guardians, as well as all involved in risk governance, will have to play a more active role than ever before in building trust with patients to ensuring that they share information confidentially with their healthcare providers in order to receive the best care possible.
Enforcement
Multiple government organisations will have to co-operate to bring a balanced sense of seriousness and enforcement to the market. The Information Commissioner Office must conduct ongoing audits of healthcare providers to ensure that they are compliant. NHS trusts which are systemically neglectful of patient privacy must be fined accordingly.
Meaningful use
It is welcome news that the government has just announced a £260 million fund for hospitals to increase their use of e-prescribing and electronic patient records. To ensure that their investment is used to best effect, and learning from what has already been implemented in the US, is the idea of linking incentive payments to achieving 'meaningful use' of electronic records. Funding should also be tied to security and privacy controls being in place.
Urgent implementation of the recommendations
Dame Fiona has demonstrated great determination to see her recommendations executed and crucial to success will be the enforcement of recommendation 26. This places the responsibility on the Secretary of State for Health to maintain oversight of the recommendations and provide an assessment of their implementation within the first 12 months. I would like to go further than this and call for the Secretary of State to report thereafter on progress made to the Health Select Committee on an annual basis.
Continuing the journey
The Caldicott recommendations mark an important step on the path towards better healthcare. If the government want to see its vision for a paperless NHS by 2018, there is no alternative but to see those recommendations implemented. The journey to realisation of electronic healthcare will be long and hard at times, but I remain optimistic as from our experience at FairWarning in the UK and the rest of the world, I know that it can be achieved.