We consider that it is in the interest of care home staff, care home residents, and the general public that information is shared with PHS to help Scottish Government maximise vaccination rates among care home staff. Older people in care homes are one of the most vulnerable groups and the Social Care Working Group of SAGE has advised that a COVID-19 vaccination uptake rate of 80% in staff and 90% in residents is needed in each individual care home to provide a minimum level of protection against outbreaks of COVID-19.
Who is PHS?
PHS is part of the National Health Service and is Scotland’s national body for improving and protecting health and wellbeing. You can learn more about PHS on its website www.publichealthscotland.scot as well as reading the COVID-19 section of its privacy notice at www.publichealthscotland.scot/our-privacy-notice/your-rights
What work is PHS and the Scottish Government doing?
PHS is collating data on vaccination uptake by care home residents and SSSC registered care home staff in individual adult care homes. PHS will share summarised data with Scottish Government so they can understand the percentage of registered staff in each care home who are vaccinated. The Scottish Government will use this information to continue to monitor progress, support vaccine uptake and identify where future promotion and delivery needs to be targeted. This may lead to more specific communication to different groups about eligibility for the vaccine and/or organising delivery of the vaccination.
What data will we share and how will PHS and Scottish Government use it?
PHS already holds limited health information for the population of Scotland and can analyse and publish uptake by vaccination priority groups. PHS is also able, from information it holds, to provide uptake rates for the NHS workforce. We’ve been asked to share data to enable PHS to identify, from the information it already holds, those individuals who are currently working in Scottish care homes for adults.
The SSSC will provide PHS with data on a quarterly basis, starting in December 2022 and ending in June 2023 (or the end of the autumn/winter vaccination programme if this is earlier than June). This is to make sure PHS has an up-to-date record of individuals working in adult care homes, so the correct population is included in their analysis.
PHS requires additional information than that which is currently available for inspection on our public Register (name, town of employment and Register part).
PHS has asked us to provide data on:
- managers of care home services for adults
- supervisors of care home services for adults
- practitioners of care home services for adults
- support workers of care home services for adults.
We will provide the following:
- Title
- Sex
- First Name
- Last Name
- DOB
- Address
- Postcode
- Care Service Number
- Care Service Name
- Care Service Postcode
- Care Service local authority area.
PHS will share with Scottish Government reports on the uptake of COVID-19 vaccinations by SSSC registered workers for each care home for adults in Scotland. Scottish Government will then share that data with directors of public health, nursing leads within health and social care partnerships, care home managers, health boards and Scottish Ministers.
How secure is my data?
We are committed to protecting the privacy and security of personal data that we hold. Our privacy statement on our website describes how we collect and use your personal data during and after your working relationship with us.
The information we share with PHS will be done securely and will be treated by PHS with the utmost security and confidentiality. To ensure this, the information we provide on your title, sex, first name, last name, date of birth, address and postcode will be removed at the earliest possible stage in the analysis and will only be accessible to a very small number of individuals at PHS. The remaining data will be accessible only to staff at PHS involved in the analysis of this data. This process ensures that the use of personally identifiable information is minimised to only what is necessary as the main aspects of the work do not require personally identifiable information.
PHS will retain your data in this way in accordance with the Scottish Government’s Records Management Health and Social Care Code of Practice (Scotland) 2020. This allows time to undertake all analytical and reporting requirements, after which it will be securely destroyed.
Information contained in the final reports produced by PHS and shared with Scottish Government will be statistical and will not identify any individual.
Why are we sharing this information with PHS?
In the Data Protection and Privacy Notice on our website there is a list of organisations/individuals with whom we may share your personal data. Our Privacy Notice says that we may share registrant information with Public Health Scotland to facilitate their public health monitoring work.
As with all requests for personal information we hold, we must carefully consider the basis upon which the information is being requested and may be shared under data protection law. When considering the legal basis for sharing the data with PHS, we have determined that Article 6(1)(f) of the UK General Data Protection Regulation (GDPR) applies: processing is necessary for the purposes of the legitimate interests pursued by a third party.
PHS has determined that Article 6(1)(e) of the GDPR applies to their processing of the data they will receive; processing is necessary for the performance of a task carried out in the public interest. PHS’s statutory duties under the Public Health (Scotland) Order 2019 include the collection, dissemination, and analysis of epidemiological data.
As PHS will also be processing the health information they already hold as part of this work, they require a further legal basis to process this under the data protection legislation. PHS has determined that Articles 9(2)(h), (i) and (j) apply to this processing and that the conditions set out in paragraphs 2, 3 and 4 of Schedule 1, Part 1 of the Data Protection Act 2018 are met, respectively, in terms of those Articles.
We have determined that there are compelling reasons for sharing the information identified with PHS; it is necessary to assist Scottish Government to manage the risk of COVID-19 in care home settings.
How do I opt out of the PHS data sharing?
The deadline for opting out 15 March 2023.
If you wish to opt out of the PHS data sharing, please complete the opt out form here. If you do opt out, we will not share your data with PHS. We will contact you to confirm this.
Alternatively, you can opt out over the telephone or in writing by contacting us on the details set out below:
Scottish Social Services Council
Compass House
11 Riverside Drive
Dundee
DD1 4NY
Email: phsenquiries@sssc.uk.com
Tel: 0345 60 30 891
Please use the SSSC contact details above for any queries.
For information about how PHS processes data, including individual’s rights and how to exercise them in relation to PHS, please see their privacy notice on their website.