Local Analytical Hub (LAH)

FDP Product Privacy Notice

Product Description

Integrated Care Boards (ICBs) are NHS organisations responsible for planning health services for their local population.

The Integrated Care Boards (ICBs) use this product to support and improve the way they manage health and care services for their local population, to provide the required care and services for the area’s population.

The Local Analytical Hub (LAH) enables ICB analysts across the area where you live to work together to understand the health and care issues across the area to help identify the actions they can take to improve your local health and care services.

Information about you is treated to make sure you cannot be identified. De-identified information is used in order to create the product.

What are the purposes for processing my personal data?

The data within the workspaces allows analysts in the Integrated Care Board (ICB) to understand the use of health and care services, identify where there are problems with delivery of care and highlight differences in care provided across communities.

What personal data about me is processed in this Product?

Personal data which has been de-identified (we call this de-identified data) will be processed by the ICB for the purposes above. De-identified data that is processed to create the Product and allow analysis to be complete may include data about: 

• Postcode
• Date of Birth
• Age
• Sex
• General Identifier
• Race or ethnicity
• Medical conditions, diagnosis and treatment [ICB to confirm]

Who is my personal data shared with?

De-identified data is securely analysed by a small number of data analysts in the ICB for the purpose of understanding how services are working and identify health services that are required across your area.

UK GDPR Information

Controllers of your personal data

Under data protection law the ICB using the Local Analytical Hub are [the Controller / Processor] of your de-identified personal data under data protection laws. The specific ICB using the Local Analytical Hub are listed on the Product Description page of the NHS England website here.

Legal grounds for processing your personal data

The processing of de-identified personal data by ICBs for the purposes explained above is permitted under the following legal grounds under data protection law (this is UK GDPR and the Data Protection Act 2018 (DPA2018)):

• Public Task – Article 6(1)(e) of UK GDPR ‘necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.
• Health Care – Article 9(2)(h) of UK GDPR ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”  In addition, the legal grounds under paragraph 2 of Part 1 of the DPA 2018 apply (health care purposes).

Common Law Duty of Confidentiality:

The Common Law Duty of Confidentiality has been set aside as the ICB has achieved a Section 251 which allows the ICB to collect this confidential data for the purposes above.

The ICB will keep your de-identified personal data confidential and only use and share it with other members of the ICB Analysts to provide the local population with health and care services and subject to strict confidentiality controls to ensure your information remains confidential.

OR

The Common Law Duty of Confidentiality has been set aside as the ICB has received this Data which is required under legal directions referred to above and issued by the Secretary of State for Health and Social Care to NHS England under section 254 of the Health and Social Care Act 2012 implemented by NHS England.]

Processor acting on behalf of ICBs

The data platform contractor, Palantir Technologies UK LTD is a processor acting on behalf of the ICB who are using this Product. They provide the data platform and the technology that the Product uses and only act on the instructions of the ICB.

IQVIA will act as a data processor in relation to ‘treating data so that a person can no longer be identified. IQVIA teams will not have access to the identifiable data processed. 

Your rights under UK GDPR

You have the following rights under UK GDPR in relation to the processing of your personal data by the ICB for the purposes above:

• Right to be informed
• Right of access
• Right to rectify
• Right to object

Further information about these rights is in the NHS Federated Data Platform Privacy Notice here.  The ICB will also have a Privacy Notice on its own website which will explain more about how the ICB processes your personal data, your rights and how to exercise them.

Does the National Data Opt Out or any other opt out apply to this Product?

Where the National Data Opt Out and Type 1 Opt Outs apply to the processing of your personal data by the organisations providing data to the ICB, the opt out will have been applied before the data is processed by the ICB.

More information

For more information about how personal data is processed within the Federated Data Platform please see the NHS Federated Data Platform Privacy Notice here.