The HSCIC is an open organisation that will carry out its activities transparently. It will demonstrate this by proactively publishing on its website its annual report and key information on areas including pay, diversity of the workforce, performance, the way it manages public money and the public benefits achieved through its activities, and by supporting those who wish to use the data by publishing the information within guidelines set by the Cabinet Office5. The annual report will include a governance statement, which is reviewed by the Senior Departmental Sponsor. The HSCIC will hold open board meetings in line with the Public Bodies (Admission to Meetings) Act 1960.
To underpin the principles of good communication, 'no surprises' and transparency, the HSCIC and the Department will put in place arrangements for managing communications. Further details are provided in Annex A.
The HSCIC's executive and non-executive board members will operate within the general principles of the corporate governance guidelines set out by HM Treasury6. They will also comply with the Cabinet Office's Code of Conduct for Board Members of Public Bodies7 and with the rules on disclosure of financial interests contained in the provisions on the membership of the HSCIC's board.
The HSCIC will develop a code of conduct for all staff which will comply with the principles in the Cabinet Office's model code for staff of executive non-Departmental
public bodies8, which includes guidance on conflicts of interest, political activity and restrictions on lobbying.
The HSCIC will take all necessary measures to ensure that:
- patient, personal and/or sensitive information within its care and control is well managed and protected through all stages of its use, including through compliance with the Data Protection Act
- it provides public assurance in respect of its information governance practice by completing and publishing an annual information governance assessment using an agreed assessment mechanism
- it meets its legal obligations for records management, accountability and public information by compliance with relevant standards, including government and NHS codes of practice on confidentiality, security and records management
The HSCIC's Senior Information Risk Owner and Caldicott Guardian will work together to ensure that both patient and other personal information are handled in line with best practice in government and the wider public sector.
Sustainability
As a major public sector body, the HSCIC has a key role to play in driving forward the government's commitment to sustainability in the economy, society and the environment. As a minimum, the HSCIC should comply with the Greening Government Commitments9 that apply to all government departments, executive agencies and non-departmental public bodies, set out in the action plan for driving sustainable operations and procurement across government. Reporting will be via the Department (including the consolidation of relevant information in the Department‟s annual resource account), and the Department will ensure that the HSCIC is aware of the process for this.
Whistleblowing
HSCIC, as with the Department and all its ALBs, should have whistleblowing policies and procedures in place that comply with the Public Interest Disclosure Act 1998 and best practice guidance10. It should prohibit the use of confidentiality clauses that seek to prevent staff from speaking out on issues of public interest.